On November 18, 2021, the Office of the Comptroller of the Currency (“OCC”), the Board of Governors of the Federal Reserve System (“Board”), and the Federal Deposit Insurance Corporation (“FDIC”) (collectively, the “Agencies”) issued a new rule (the “Rule”) that…
On October 27, 2021, the Federal Trade Commission (“FTC”) announced new updates to the Gramm-Leach-Bliley Act (“GLBA”) by amending the Standards for Safeguarding Customer Information, known as the “Safeguards Rule,” and issuing a final rule (the “Final Rule”). The Safeguards…
In the wake of the COVID-19 crisis, much of the workforce has shifted to working remotely, with many workers operating out of makeshift “offices” they created in their homes with little or no warning. Along with this remote work comes…
As data breaches are on the rise, the old adage rings true: it’s not a question of if, but when. More companies are experiencing crippling breaches and the statistics are alarming: According to IBM Security’s Cost of a Data Breach…
It is evident that a company must invest in its privacy practices to meet legal requirements if it wants to avoid investigation costs and potential civil penalties. But can investment in privacy, data security, and data management bring benefits to…
With so much attention being paid to the impending California Consumer Privacy Act, it can be easy to forget that other states have privacy and data security laws too. And those laws change routinely, with potentially significant impacts on businesses. …
Well thought-out internal privacy policies and procedures are an essential part of any company’s information management program. These internal policies should not be confused with a company’s external privacy notice, which informs the company’s customers as to how it may…
With all of the hubbub swirling around Capitol Hill last week with the Michael Cohen hearings, you can’t be blamed if you missed the fact that two important congressional hearings on privacy and data protection took place as well, one…
Since the 1970’s, fair information practices (FIPs) or fair information privacy practices (FIPPs) have formed the framework around which organizations structure their policies on data collection, use, disclosure, and retention. The cornerstone of individual privacy rights under the FIPs is…
On December 12, 2018, Senator Schatz (D-HI), along with 15 other Senators, introduced the Data Care Act of 2018 “to establish duties for online service providers with respect to end user data that such providers collect and use.” The bill…
