Information Governance and Risk Management

On November 15, 2017, the Trump administration released the Vulnerabilities Equities Policy and Process. This document describes the process by which U.S. agencies and departments determine whether to disclose or restrict information on vulnerabilities in information systems and technologies. The Vulnerabilities Equities Process (VEP) balances whether to disclose vulnerability information to the vendor or supplier

On August 7 2017, the U.S. Securities and Exchange Commission (SEC), through its Office of Compliance Inspections and Examinations (OCIE), published a Risk Alert summarizing observations on how broker dealers, investment advisers, and investment companies have addressed cybersecurity issues. The OCIE examined 75 financial firms registered with the SEC. The examinations focused on the firms’

This month, the Federal Trade Commission (FTC) issued guidance for businesses operating websites and online services looking to comply with the Children’s Online Privacy Protection Act (“COPPA”). COPPA addresses the collection of personal information from children under 13.  Importantly, the determination of whether a business’s website is “directed to children under 13” (and thus subject

On May 31, 2017, the Federal Financial Institutions Examination Council (FFIEC) released an update to its Cybersecurity Assessment Tool.

The Cybersecurity Assessment Tool was originally released by the FFIEC in June of 2015 to help financial institutions identify their risks and assess their cybersecurity preparedness.  The Cybersecurity Assessment Tool is intended to be used by

On March 10, 2017, the White House Office of Management and Budget (“OMB”) released its 2016 Federal Information Security Modernization Act (“FISMA”) Annual Report to Congress. The FISMA Report describes the current state of Federal cybersecurity. It provides Congress with information on agencies’ progress towards meeting cybersecurity goals and identifies areas that need improvement. Additionally,

Vintage toned Wall Street at sunset, NYC.

Today, acting FTC Chairman Maureen K. Ohlhausen and FCC Chairman Ajit Pai issued a joint statement on the FCC’s issuance of a temporary stay of a data security regulation for broadband providers scheduled to take effect on March 2.  In their statement, they advocate for a “comprehensive and consistent framework”, so that Americans do not

In a recent announcement today, Verizon and Yahoo have announced that they are amending the existing terms of their agreement for the purchase of Yahoo’s operating business.  Under the amended terms, Verizon and Yahoo have agreed to reduce the price Verizon will pay by $350 million.  In addition, Yahoo will be responsible for 50% of

On January 10, 2017, NIST issued an update to the NIST Cybersecurity Framework (v.1.1).  After reviewing public comment and convening a workshop, NIST intends to publish a final version of this Version 1.1 in the fall of 2017.

Key updates the framework include:

  • Metrics.  A new section 4.0 on Measuring and Demonstrating Cybersecurity to

Connected cars and autonomous cars conceptAfter its recent release of guidelines regarding self-driving cars, the National Highway Traffic Safety Administration released a set of “best practices” for cybersecurity in vehicles.  The 22-page document encourages auto manufacturers to proactively incorporation security in their efforts a matter of course (e.g., privacy by design).  The guidelines recommend a “layered approach” of protections,

AftDeveloping new programer surveying nearly 200 regulated financial institutions to obtain insight into the industry’s efforts to prevent cybercrime and meeting with a cross-section of those surveyed, as well as cybersecurity experts, to discuss emerging trends and risks, as well as due diligence processes, policies and procedures governing relationships with third party vendors, the New York State Department of Financial Services (NYDFS) recently released its proposed cyber security regulation.  The proposed regulation, titled “Cybersecurity Requirements for Financial Services Companies”, if implemented, would be a first-in-the-nation provision that requires a mandatory cybersecurity program for financial institutions.


Continue Reading