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|PCI DSS Version 3.1—SSL and Early Versions of TLS Are Deemed No Longer Secure|
Rachel A. Geist, Todd S. McClelland, Mauricio F. Paez, Gregory P. Silberman; Jones Day;
May 7, 2015, previously published on April 2015On April 15, 2015, the Payment Card Industry Security Standards Council ("SSC") released Version 3.1 of the Payment Card Industry Data Security Standard ("PCI DSS"). PCI DSS is a set of standards that dictate how merchants and other organizations in the payment cycle are...
|State of the Union Address Places the President's Privacy and Cybersecurity Proposals Front and Center|
Richard J. Johnson, Todd S. McClelland, Mauricio F. Paez, Gregory P. Silberman; Jones Day;
February 27, 2015, previously published on January 2015In his January 20, 2015, State of the Union Address, President Barack Obama notably focused on privacy and cybersecurity, stressing the urgent need for comprehensive legislation. He raised the specter of foreign nations and hackers shutting down American networks, stealing trade secrets, and...
|FINRA and SEC Issue Cybersecurity Reports Identifying Common Industry Practices|
Kyle T. Barrett, Richard J. Johnson, Todd S. McClelland, Mauricio F. Paez, Gregory P. Silberman; Jones Day;
February 26, 2015, previously published on February 2015New reports by the Financial Industry Regulatory Authority ("FINRA") and the SEC's Office of Compliance Inspections and Examinations ("OCIE") highlight the increased regulatory focus in the financial sector on cybersecurity. Both reports merit industry attention.
|President Obama Continues Push on Cybersecurity|
Todd S. McClelland, Michael G. Morgan, Mauricio F. Paez, Katherine S. Ritchey, Gregory P. Silberman; Jones Day;
February 26, 2015, previously published on February 2015On February 13, 2015, President Obama spoke to attendees of the White House Summit on Cybersecurity and Consumer Protection held at Stanford University. Calling the digital world a "sort of Wild Wild West," Obama and many corporate representatives announced developments intended to...
|New York Regulator Announces Plans to Conduct Targeted Cybersecurity Examinations of Insurance Companies, Issue Standards|
Matthew R. Bowles, Scott A. Edelstein, Lisa M. Ledbetter, Mauricio F. Paez; Jones Day;
February 26, 2015, previously published on February 2015On February 8, 2015, the New York State Department of Financial Services ("NYDFS") announced that it will soon begin making targeted cybersecurity assessments of insurance companies and that it plans to issue regulations setting heightened security standards. The announcement coincides...
|New Telecommunications Privacy Rules for U.S. Broadband Providers|
Bruce A. Olcott, Mauricio F. Paez, Preston N. Thomas; Jones Day;
February 26, 2015, previously published on February 2015Turn-of-the-century common carrier regulation is about to be imposed on providers of broadband internet services in the United States; all that remains to be determined is the details, and there are a lot of them in dispute. On February 4, 2015, Chairman Tom Wheeler of the Federal Communications...
|President Signs End-Of-Year Cybersecurity Legislation Into Law|
Nandini Iyer, Richard J. Johnson, Gabriel Morris Ledeen, Mauricio F. Paez, Katherine S. Ritchey; Jones Day;
February 25, 2015, previously published on December 2014On December 18, 2014, President Obama signed into law five cybersecurity-related bills that address concerns recently brought to the forefront by highly publicized intrusions into public and private networks.
|FDA Voices Privacy Concerns and Promotes Medical Device Cybersecurity with New Guidance, Collaborative Information-Sharing|
Laurie A. Clarke, Alexis Slagle Gilroy, Colleen Heisey, Kevin D. Lyles, Mauricio F. Paez; Jones Day;
December 16, 2014, previously published on November 2014Cybersecurity of medical devices poses unique challenges for industry and regulators, because of potential risks in device malfunction, disruption of medical care, and compromised patient data, as well as the challenge of balancing countervailing needs, such as patient safety and ensuring that...
|CFPB Permits Online Posting of Annual Privacy Notices|
Michael R. Butowsky, Lisa M. Ledbetter, Todd S. McClelland, Stephen J. Obie, Mauricio F. Paez; Jones Day;
December 16, 2014, previously published on November 2014The Consumer Financial Protection Bureau ("CFPB") recently adopted a final rule that under certain conditions provides financial institutions it regulates with the option of posting annual consumer privacy notices online rather than mailing paper copies to customers (the "Privacy...
|California Attorney General Calls for Greater Data Protection, and Recommends Adoption of Chip and Pin Payment Card Technology|
Michael G. Morgan, Mauricio F. Paez, Katherine S. Ritchey, Gregory P. Silberman, Olivia C. White; Jones Day;
November 12, 2014, previously published on October 2014Data breaches are on the rise-and so is government enforcement action and data breach litigation. Retailers are not the only ones at risk; data breaches are affecting a growing number of industries. In addition to recent privacy enforcement actions from the Federal Trade Commission and now the...