On October 11, 2024, the Department of Defense (“DoD”) issued its Final Program Rule for the Cybersecurity Maturity Model Certification (“CMMC”) Program. The Final Rule is a signal to federal contractors to develop compliance programs pertaining to CMMC in advance of the implementation of CMMC (likely next year). The CMMC program is designed to ensure […]
Data Protection
SEC 2025 Examination Priorities Indicate Sustained Focus on Cybersecurity & Data Protection
The SEC has released its Examination Priorities: Fiscal Year 2025 (“Examination Priorities”), which may be a useful roadmap to SEC-registered investment advisers, exchanges, and other entities subject to routine examination by the SEC Division of Examinations (“EXAMS”). The Examination Priorities represent the EXAMS Staff’s identification of areas of heightened risks to investors and/or the integrity […]
EDPB Adopts Opinion on the Use of Processors and Sub-processors
On October 7, 2024, the European Data Protection Board (“EDPB”) adopted an opinion on obligations following from the use of processors and sub-processors (the “Opinion”). The EDPB is the body that seeks to ensure harmonised application of the EU GDPR across the European Economic Area (“EEA”) and is comprised of the heads of the data […]
Department of Justice Intervenes in Cybersecurity Qui Tam Action Against Georgia Tech
On Thursday, August 22, 2024, the United States Department of Justice (“DOJ”) filed a Complaint-In-Intervention in the case of United States of America ex rel. Christopher Craig and Kyle Koza, v. Georgia Tech Research Corp. and Board of Regents of the University System of Georgia (d/b/a the Georgia Institute of Technology) (United States v. Georgia […]
New York Attorney General Investigates Companies for Website Tags, Publishes Guidelines on Online Tracking Technologies
On July 30, 2024, the New York Attorney General Letitia James announced she had completed an investigation into the tracking technology practices of popular websites, and used this to create website privacy guides on online tracking for New York businesses and consumers. These consist of a “Business Guide” and a “Consumer Guide.” The Business Guide […]