cybersecurity

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On July 26, 2023, the U.S. Securities and Exchange Commission (SEC) announced that it adopted final rules requiring disclosure by public companies of material cybersecurity incidents in a Current Report on Form 8-K, and of material information regarding their cybersecurity risk management, strategy, and governance in an Annual Report on Form 10-K. Foreign private issuers will be required to make comparable disclosures on Forms 6-K and 20-F. Set forth below is a brief summary of the final rules; a more detailed client alert will follow.Continue Reading SEC Adopts Cybersecurity Disclosure Rules

On May 22, 2023, Ireland’s Data Protection Commission (DPC) published its long-awaited decision in the Meta EU-U.S. data transfer case (Decision). In its landmark Decision, the DPC imposed a record 1.2 billion EUR fine and…

Continue Reading Meta Receives Record 1.2 Billion EUR Fine and Is Ordered to Suspend Its EU-U.S. Data Transfers

On March 2, 2023, the White House released its National Cybersecurity Strategy (the Strategy). The Strategy sets out ambitious goals for the federal government to hold countries accountable for irresponsible behavior in cyberspace and to…

Continue Reading White House Releases National Cybersecurity Strategy: Key Takeaways for the Private Sector

Since the invalidation of the Privacy Shield framework in 2020 in the “Schrems II” case, the EU and the U.S. have been working to set up a new framework for data flows from…

Continue Reading EU Regulators Adopt Opinion on Draft EU-U.S. Data Privacy Framework

On January 27, 2023, the California Attorney General (California AG) Rob Bonta announced an “investigative sweep” of mobile apps in retail, travel, and food service industries for failing to provide a mechanism for—or honor—consumers’ opt-out…

Continue Reading California AG Targets Mobile Apps for Failing to Honor or Provide Mechanism for Opt-Out Requests