On January 16, 2020, the National Institute of Standards and Technology (“NIST”) published Version 1.0 of its Privacy Framework: A Tool for Improving Privacy through Enterprise Risk Management (“Privacy Framework”). A draft version was initially published for public comment on September 6, 2019. The new Privacy Framework is designed to support organizations in building customer’s […]
Data Security
FTC Consumer Protection Bureau Director Highlights Efforts to Strengthen Data Security Orders
On January 6, 2020, the Federal Trade Commission’s (FTC) Bureau of Consumer Protection Director Andrew Smith published a blog post summarizing the agency’s “New and improved FTC data security orders,” as part of its efforts to provide “better guidance for companies” and “better protection for consumers.” Smith noted that strengthening the FTC’s orders in data […]
Treasury Announces Sanctions Against Cybercriminal Group Behind ‘Dridex’ Malware, Offering Mitigation Strategies for Businesses
On December 5, 2019, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) issued sanctions against Evil Corp, a Russian cybercriminal organization that is known for distributing the Dridex malware. Dridex is a banking trojan that has been used to target financial institutions across the globe and has resulted in more than $100 million […]
Critical Audit Matters Disclosure Implicates Information Technology and Security
As independent auditors to public companies and business development companies begin to make required disclosure of Critical Audit Matters (CAMs) to the audit committee, such reports are beginning to include discussion of information security programs and information technology controls. Independent auditors have treated material weaknesses in certain information technology controls as material weaknesses in internal […]
SHIELD Act Overhauls New York’s Data Breach Notification Framework
On October 23, 2019, New York’s new breach notification provisions came into effect, a result of New York’s passage of the Stop Hacks and Improve Electronic Data Security Act (SHIELD Act) in July. That Act overhauled New York’s data privacy framework, expanding the list of data elements that are considered “private information” while growing the […]