Entries by Sasha Hondagneu-Messner

Risk Analysis in the Crosshairs: Four Recent Ransomware Resolutions Preview the HIPAA Security Rule Amendments

On April 23, 2026, the U.S. Department of Health and Human Services’ (HHS) Office for Civil Rights (OCR) announced resolution agreements and corrective action plans with four regulated entities following separate ransomware investigations under the Health Insurance Portability and Accountability Act of 1996 (HIPAA) Security Rule. The settlements are the culmination of OCR investigations into separate ransomware breaches collectively affecting more than 427,000 individuals and involving the exposure of unsecured electronic protected health information (ePHI) – demographic data, Social Security numbers, financial information, lab results, medications, and diagnoses or conditions. Under the settlements, the regulated entities agreed to implement corrective action plans subject to OCR monitoring for two years and pay a total resolution amount of $1,165,000 to OCR.

New York Department of Financial Services (NYDFS) Clarifies Expectations for Third-Party Cybersecurity Risks Under its Cybersecurity Regulation, and Additional Amendments Go into Effect on November 1, 2025

On October 21, 2025, NYDFS, the New York State agency responsible for regulating financial services and products, issued an Industry Letter clarifying how “Covered Entities”[1] should manage cybersecurity risks arising […]

California Privacy Protection Agency Advances Substantial Rulemaking – Cyber Audits, Risk Assessments, New Automated Decisionmaking Technologies Rights, and More

The California Privacy Protection Agency (Agency) on Thursday, July 24, 2025, approved a comprehensive set of new California Consumer Privacy Act (CCPA) regulations that the Agency has been developing for […]