Madeline Cimino

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On October 27, 2023, the Federal Trade Commission (FTC) announced it is amending the Safeguards Rule of the Gramm-Leach-Bliley Act (GLBA) to include a requirement for non-bank financial institutions to report certain data breaches and other security events to the agency.Continue Reading FTC Amends Safeguard Rule with Requirement for Non-Banking Financial Institutions to Report Data Security Breaches

Reflective of the Government’s increasing focus on cybersecurity, on October 3, 2023, the Federal Acquisition Regulation Council (FAR Council) released two new proposed rules that will have major impacts on federal contractors. These rules implement the May 2021 Executive Order on Improving the Nation’s Cybersecurity.1 One rule applies to any federal contractor that uses information and communications technology (ICT) systems in the performance of a federal contract, sets forth cybersecurity incident reporting requirements, and imposes a software bill of materials (SBOM) requirement. The other rule, which applies only to those federal contractors that provide or maintain a Federal Information System (FIS), is intended to standardize cybersecurity requirements for unclassified FISs.Continue Reading New Proposed Rules Published for Cyber Incident Reporting and Cybersecurity Requirements Will Have Major Impacts on Federal Contractors

Significant New CCPA Compliance Requirements Likely on the Way

On August 29, 2023, the California Privacy Protection Agency (CPPA) posted discussion drafts of its forthcoming regulations on cybersecurity audits and risk assessments as part of the materials for its September 8, 2023, public board meeting. These draft regulations are expected to eventually become part of the CPPA’s second rulemaking package under the California Consumer Privacy Act (CCPA) since the CCPA’s amendment by the California Privacy Rights Act. The CPPA has not yet started its formal rulemaking process for cybersecurity audits and risk assessments, and it has made clear that these draft regulations are meant to facilitate CPPA Board discussion and public participation. Nevertheless, the obligations set forth in the draft rules are extensive and provide an initial window into the onerous new compliance requirements. Notable requirements put forth for discussion under the draft regulations include:Continue Reading CPPA Posts Draft Rules on Cybersecurity Audits and Risk Assessments