Written Information Security Program

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Any illusion an organization may hold that it is operating “under the radar” of regulators should be shattered in the current compliance environment. Governmental agencies are increasingly able to efficiently coordinate with one another in matters of enforcement, and this post is a good example of that.
Continue Reading Inter-agency Cooperation Nabs HIPAA Violator for HHS

Promising a company that you will safeguard its employees’ information and then failing to do it according to Federal Trade Commission (FTC) standards likely will be viewed by the FTC as an unfair and deceptive business practice and trigger an enforcement action.

This was the case for Lookout Services, Inc., a company that maintains large amounts of…

The National Association of Secretaries of State has recognized that the newest victims of identity theft are small and medium-sized businesses. These businesses need to take steps to safeguard not only personal information of customers, employees and others, but also the businesses’ corporate and financial data.
Continue Reading Small to Mid-Sized Businesses Wake Up! The National Association of Secretaries of State Warns Identity Theft Does Not Just Hurt Individuals

CDPH’s data privacy enforcement activity continues, this time affecting 6 hospitals and a nursing home with total penalties approaching $800,000.
Continue Reading California Department of Public Health Continues to Fine Hospitals and Nursing Homes for Data Breaches

We’ve written extensively here on the importance of safeguarding personal information. We’ve also made clear that the safeguarding of data should not stop with individually identifiable personal information. In fact, many times a company’s most sensitive information, data critical to the survival of its business, is its corporate trade secrets, proprietary information, and its clients’…

As reported by the American Bar Association and PHIprivacy.net, lawyers, accountants, health care providers and others soon may get some clarity as to whether the "red flag" rules apply to them. The United States Senate voted unanimously to pass the Red Flag Program Clarification Act of 2010. Under the Act, according to statements from Sen.

In March 2010, we reported on a decision by the U.S. District Court for the District of New Jersey that allowed an employee’s retaliation claim to proceed to trial under the New Jersey Conscientious Employee Protection Act (“CEPA”) on the ground that he was engaged in protected whistle blowing activity – voicing concerns regarding his employer’s …

Federal contractors are subject to numerous requirements under federal law and, as we have previously highlighted here, need to keep pace with changes in law and regulation. 

Under the Federal Information Security Management Act of 2002 (FISMA) each federal agency is required to develop, document, and implement an agency-wide program to provide information security …

A UK law firm may find itself subject to significant penalties following reports of a data breach affecting thousands of people.  The recent 2010 ABA Annual Meeting in San Francisco devoted two sessions to the topic, specifically dealing with “cloud computing,” and the risks and ethical issues it raises for law firms. As data privacy and security risks…