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|NIST's Privacy Risk Management Framework Released in Draft Report|
Todd S. McClelland, Daniel J. McLoon, Michael G. Morgan, Mauricio F. Paez, Gregory P. Silberman; Jones Day;
June 22, 2015, previously published on June 2015On May 29, 2015, the National Institute of Standards and Technology ("NIST") released Privacy Risk Management for Federal Information Systems (NISTIR 8062) as a draft report, introducing its newly developed Privacy Risk Management Framework ("Privacy Framework"). The stated...
|Doing Business with the Government? What You Should Know about Cybersecurity|
Peter F. Garvin, J. Andrew Jackson, Fernand A. Lavallee, Todd S. McClelland, Mauricio F. Paez; Jones Day;
June 8, 2015, previously published on June 2015Government contractors are in a difficult position when it comes to cybersecurity. Not only do they need to worry about cybersecurity issues that affect almost every company, but they also often house sensitive government data that can carry additional obligations. Further, the very fact that they...
|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.
|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...
|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...
|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...
|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.
|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...