Multi‑factor authentication (MFA) is now a well-established baseline cybersecurity control. The amended New York Department of Financial Services (NY DFS) solidified that understanding and expanded MFA requirements under 23 NYCRR Part 500 (the NY DFS
Cybersecurity and Personal Data: The CNIL toughens its stance
On 9 February 2026, the Commission Nationale de l’Informatique et des Libertés (CNIL) published its 2025 report on its enforcement action. Beyond the €487 million – in cumulative fines – largely driven (unsurprisingly) by two sanctions related to cookies, another…
Getting ready for California’s new cybersecurity audit requirements
On January 1, 2026, the California Privacy Protection Agency’s (“CalPrivacy”) cybersecurity audit regulations (the “Regulations”) took effect after several years of rulemaking and public comment. As previewed in the Data Protection Report, certain businesses subject to the California Consumer…
HHS and state AGs fine ambulance firm over $500,000, require enhanced security, privacy, and data minimization practices
Earlier this year, the Attorneys General of Massachusetts and Connecticut entered into settlement agreements with Comstar, LLC, an ambulance billing firm, relating to alleged HIPAA regulation violations in connection with a ransomware incident. Comstar is a business associate under HIPAA…
Heightened Cyber Risks in the Middle East: Geopolitical Tensions Fuel Digital Conflict
Introduction
The latest developments in the Middle East – marked by a significant surge in military activity and retaliatory strikes across the region – have been accompanied by a parallel intensification of cyber operations.
It is common in such situations…
AI and privilege: Assessing recent court rulings
We recently drafted an article that discussed court decisions that reached very different conclusions about how the attorney-client privilege and work product doctrine apply to materials submitted to and created by generative AI (GenAI) tools. A recent decision from the…
Protective order violations lead to sanctions in Uber MDL litigation
Even when stringent protective orders are in place, clients are often concerned that the sensitive information they are required to produce in litigation will end up being disclosed or used for improper purposes. Clients often ask whether the protective order…
Celebrating Global Information Governance Day: Why information governance matters more than ever
Happy Global Information Governance Day!! Today we celebrate information governance and raise awareness of how to manage data, balance risks and build a culture focused on good data hygiene.
Working with large and small companies around the world, we have…
Partial compliance is noncompliance: Lessons from California’s $2.75 million settlement with Disney
On February 11, 2026, California Attorney General Rob Bonta announced a $2.75 million settlement with The Walt Disney Company (“Disney”), the largest civil penalty to date under the California Consumer Privacy Act as amended by the California Privacy Rights Act…
The DOJ’s civil cyber-fraud initiative lives on: Insights from cybersecurity enforcement through the False Claims Act
The False Claims Act (“FCA”), the U.S. federal government’s principal civil anti-fraud statute, imposes liability on entities that knowingly submit, or cause the submission of, false or misleading claims for payment to the United States. The FCA has long served…