On July 10, the SEC’s Office of Compliance Inspections and Examinations (OCIE) issued a Risk Alert noting the increasing sophistication of ransomware attacks on SEC registrants and service providers to SEC registrants. The Risk Alert is notable for its encouragement of financial services market participants more broadly and not just SEC registrants to monitor CISA […]
Data Security
Japan’s Personal Information Protection Committee releases guidance on contact tracing mobile apps to combat COVID-19
On May 1, the Personal Information Protection Committee in Japan (PPC) released guidance on the use of contact tracing mobile apps (Apps) as one of the mechanisms to combat the spread of COVID-19 and highlighted five essential consideration points. Specifically, the PPC recommends that all “personal information handling business operators” carefully consider, and disclose their […]
CCPA Plaintiffs Testing whether Any CCPA Violation Can be Used to Bring Class Actions
Plaintiffs’ counsel have started to lay the groundwork in the last few weeks for a broad private right of action under the California Consumer Privacy Act (the “CCPA”). Alston & Bird has published an Advisory that evaluates this recent CCPA litigation, and offers practical advice to companies as they build CCPA compliance. In this Advisory, […]
Location and Mobile Data in the Fight against COVID-19 – An Overview of U.S. and Global Efforts
Governments are increasingly seeking to leverage consumer geolocation and other mobile device data to assist with fighting the spread of COVID-19, as cases continue to mount globally. Location data can be of significant value to public health models, such as models that determine areas where social-distancing measures are needed or test whether such measures are […]
SEC Releases Detailed Set of “Cybersecurity and Resiliency Observations”
On January 28, 2020, the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) released a detailed set of observations culled from thousands of examinations of registered investment advisers, broker-dealers, clearing agencies, national exchanges, and other SEC registrants (“Observations”). These Observations represent the most detailed compilation of strategies and tools that OCIE has observed to promote […]