Cybersecurity Takeaways From White House Tech Report
On Feb. 26, the White House’s Office of the National Cyber Director (ONCD), released a report on how technology manufacturers and software developers can improve the cybersecurity posture of the U.S. This report, “Back to the Building Blocks: A Path Toward Secure and Measurable Software,” aligns with the Biden administration’s current, intense focus on combatting ever-increasing cyberthreats through software development and software manufacturer accountability. In this article, published by Law360 on March 26, Sidley lawyers Alan Charles Raul, Stephen McInerney and Vishnu Tirumala discuss the ONCD report and provide key take-aways for software developers and manufacturers, their senior management, and boards.
FTC Proposes Significant and Sweeping Changes to COPPA and Requests Public Comment
On January 11, 2024, the Federal Trade Commission (“FTC”) published its Notice of Proposed Rule Making (“NPRM”) seeking to update the FTC’s Children’s Online Privacy Protection Act (“COPPA”) Rule in the Federal Register. Among other things, the proposed changes would require more granular privacy notices, require fairly detailed identification of, and parental consent to, third-party data sharing (including targeted advertising), expand the scope of personal information subject to COPPA, make it easier for parents to provide consent via text message, clarify various requirements around EdTech, including school authorization for parental consent, and impose significant new programmatic information security and data retention requirements.
UK Publishes Cyber Governance Code of Practice for Consultation
On 23 January 2024, the UK government published its draft Cyber Governance Code of Practice (the “Code”) to help directors and other senior leadership boost their organizations’ cyber resilience. The draft Code, which forms part of the UK’s wider £2.6bn National Cyber Strategy, was developed in conjunction with several industry experts and stakeholders – including the UK National Cyber Security Centre. The UK government is seeking views from organizations on the draft Code by 19 March 2024.
