On March 2, the federal Consumer Financial Protection Bureau (CFPB) for the first time brought an enforcement action related to data security. The CFPB consent order imposes a $100,000 fine and five years of regulatory oversight for online payments provider Dwolla. The action sends a clear message that the CFPB intends to actively regulate the […]
Enforcement
WP 29 Issues Statement on EU-U.S. Privacy Shield
On the same day that the European Commission debuted the EU-U.S. Privacy Shield, the Article 29 Working Party (WP29) issued a statement welcoming the publication of the draft “adequacy decision” of the European Commission as well as the legal texts that constitute the Privacy Shield arrangement. In accordance with its mission, WP29 said that it would […]
SEC Continues to Focus on Cyber-related Disclosures
Participating in a panel at the “SEC Speaks” event on February 19, Deputy Director of the SEC’s Enforcement Division Stephanie Avakian expressed that the Commission continues to focus on cybersecurity as a top priority in 2016. Avakian discussed the Commission’s cybersecurity concerns in three contexts: (1) failure of registered entities to follow Rule 30(a) of […]
President Obama Announces Cybersecurity National Action Plan
On February 9, 2016, President Barack Obama unveiled his new Cybersecurity National Action Plan (CNAP), a comprehensive approach to confront cybersecurity challenges. As articulated in the CNAP Fact Sheet released by the White House, CNAP takes “near-term actions and puts in place a long-term strategy to enhance cybersecurity awareness and protections, protect privacy, maintain public […]
EU Working Party Discusses Data Transfer Framework
Today, the consortium of European data protection authorities, the Article 29 Working Party (“WP29”), released a much awaited statement on the consequences of the European Court of Justice (“ECJ”) decision that invalidated the Safe Harbor framework. Companies will be relieved to find that alternative transfer mechanisms, such as Model Contracts or Binding Corporate Rules, are […]