Category

Information Security

26 February 2019

NERC $10,000,000 Fine of Public Utility Highlights the Need for Cybersecurity Preparedness and CIP Compliance Programs

On January 25, 2019, the North American Electric Reliability Corporation (“NERC”) asked the Federal Energy Regulatory Commission (“FERC”) to approve a settlement issuing a record $10 million fine against an unidentified utility resulting from violations of critical infrastructure protection standards (“CIP”) occurring mostly between 2015 and 2018 (referred to hereafter … Read More

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11 February 2019

Michigan Adopts National Association of Insurance Commissioners’ (NAIC) Insurance Data Security Model Law

On December 28, 2018, Michigan adopted the National Association of Insurance Commissioners’ (NAIC) Insurance Data Security Model Law in the form of Michigan H.B. 6491 (Act). By doing so, Michigan joins Ohio and South Carolina as the third state to adopt the Model Law and the fifth state – along … Read More

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29 January 2019

FINRA Issues Its 2019 Risk Monitoring and Examination Priorities Letter

On January 17, the Financial Industry Regulatory Authority (FINRA) released its annual Risk Monitoring and Examination Priorities Letter (Letter), which identifies topics that FINRA will focus on in 2019. Unlike in previous years, this Letter primarily discusses new topics and priorities in areas of ongoing concern while not repeating topics … Read More

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14 January 2019

Ohio Adopts National Association of Insurance Commissioners’ (NAIC) Insurance Data Security Model Law

On December 19, 2018, Ohio adopted the National Association of Insurance Commissioners’ (NAIC) Insurance Data Security Model Law.  By doing so, Ohio joins South Carolina as the second state to have adopted the Model Law and the fourth state – along with Connecticut and New York – to have enacted … Read More

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08 January 2019

HHS Releases Cybersecurity Guidance for Healthcare Organizations

On December 28, 2018, the U.S. Department of Health and Human Services (HHS) released a four-volume cybersecurity guidance document for healthcare organizations. The publication, “Health Industry Cybersecurity Practices: Managing Threats and Protecting Patients” (HICP), is the result of a government and industry collaboration mandated by the Cybersecurity Act … Read More

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29 October 2018

FERC Approves NERC’s Supply Chain Risk Management Reliability Standards and Directs NERC to Expand Their Scope

A string of Governmental announcements have increasingly sounded the alarm about the growing cybersecurity threat facing the energy sector.  Among other things, these reports have announced that state-sponsored cyber actors have successfully gained access to the control rooms of utilities.  The hackers, one of the reports notes, could have used … Read More

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25 October 2018

SEC Cautions Public Companies to Address Cyber Threats as Part of Internal Accounting Controls

On October 16, 2018, the U.S. Securities and Exchange Commission (SEC) took the unusual step of issuing a Report of Investigation cautioning public companies that they should consider cyber threats and related human vulnerabilities when designing and implementing their internal accounting controls. The report is an outgrowth of an investigation … Read More

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09 October 2018

Highlighting the Chinese Cybersecurity Law

Former Department of Homeland Security Chief Privacy Officer Hugo Teufel III and Sidley’s Edward McNicholas addressed a packed room on Chinese Cybersecurity Law at the 2018 Privacy + Security Forum hosted at George Washington University.  The timely presentation highlighted how, with significant attention in the past few years focused on … Read More

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05 October 2018

White House and Pentagon Announce New Cyber Strategies

The Trump Administration continued to put its stamp on federal cybersecurity policy last week, as the White House issued its National Cyber Strategy while the Pentagon announced the Department of Defense Cyber Strategy.  The former document is a helpful step forward that continues and advances the cyber policies the Trump … Read More

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25 September 2018

Movement Towards a Comprehensive U.S. Federal Privacy Law: Witnesses Prepare to Testify in Senate Hearing

The last six months have been busy ones for privacy watchers, with the entry into force of the GDPR and the enactment and amendment of the California Consumer Privacy Act.

An increasing number of eyes are now turning to the U.S. Congress to see how it will react to these … Read More

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