Exploring the evolution of cybersecurity and privacy law
On November 1, 2023, the New York Department of Financial Services (“NYDFS”) finalized the amendment to its cybersecurity regulation (the “Amendment”). The Amendment expands cybersecurity requirements across many areas—from governance to incident response to access controls.
The Amendment follows the three published drafts: two proposals published for formal notice and comment in November 2022 and…
The Second Amendment to the New York Department of Financial Services’ (“NYDFS”) Cybersecurity Requirements for Financial Services Companies (the “NYDFS Requirements”) is expected to be published in final form in the next two weeks. The Second Amendment will follow updated proposed amendments to the NYDFS Requirements published on June 28, 2023 (the “2023 Proposal”),1…
Oregon has joined 10 other states in enacting a comprehensive data privacy law.1 On July 18, 2023, Governor Tina Kotek signed the Oregon Consumer Privacy Act (the “Oregon Privacy Law”) into law. The law imposes a range of new data privacy requirements on non-exempt controllers and processors of Oregon consumer personal data. The Oregon…
The New York Department of Financial Services (NYDFS) has proposed revisions to its cybersecurity regulation for banks, insurance companies and other financial services companies. The proposal significantly expands requirements for covered entities, including new requirements for larger companies, expanded governance requirements, additional notice and compliance certification requirements and more.
In this one-hour webinar, members of…
On June 28, 2023, the New York Department of Financial Services (“NYDFS”) published updated proposed amendments to its cybersecurity regulation (the “2023 Proposal”) applicable to “covered entities.”1 Covered entities are any person operating under, or required to operate under, a license, registration, charter, certificate, permit, accreditation or similar authorization under the New York Banking…
On June 18, 2023, Governor Greg Abbott signed into law the Texas Data and Privacy Security Act (the “Texas Privacy Law”), which goes into effect July 1, 2024. With this law, Texas joins 10 other states that have also passed comprehensive privacy laws throughout the United States: California, Virginia, Colorado, Connecticut, Utah, Florida, Montana, Iowa,…
The California Privacy Protection Agency (“the Agency”) announced October 17, 2022, proposed modifications to the draft regulations for the California Privacy Rights Act (CPRA) that were published on July 8, 2022. The draft regulations expanded on the text of the CPRA setting out a number of additional requirements regarding obtaining consumer consent, supporting the exercise…
There has been a whirlwind of activity over the past year as states enact and implement comprehensive consumer privacy laws. Starting with the passage of the California Consumer Privacy Act (CCPA) in 2018, which became effective in 2020, the US state privacy legal landscape has continued to develop rapidly. New comprehensive privacy frameworks are set…
The California Privacy Rights Act (CPRA) will go into effect on January 1, 2023, even though the draft regulations remain unsettled, leaving companies questioning their ability to comply. In this talk with Jennifer Barrera of CalChamber, we’ll discuss some of the outstanding issues that will have impacts in the state, across the country, and, indeed,…
As cybersecurity and privacy risks mount, financial services companies face new concerns about compliance and enforcement as well as the risk of business interruption and costly litigation. In this Cybersecurity Awareness Month program, our lawyers will discuss the recent regulatory developments from the New York Department of Financial Services (NYDFS) that are presenting real-world challenges…
