On November 25, 2024, the New York State Department of Financial Services (“NYDFS”) announced it settled with two large insurance companies over allegations of inadequate data security practices in violation of New York’s cybersecurity regulation (23 NYCRR Part 500) (the
Dan Pepper (US)
Department of Defense proposes requirements for assessing contractor cybersecurity
Background
On August 15, 2024, the Department of Defense (DoD) proposed amending the Defense Federal Acquisition Regulation Supplement (DFARS) to evaluate contractor cybersecurity (Cybersecurity Assessment Proposed Rule). Contractors already need documented, adequate security for handling sensitive information, but the proposed…
CISA issues proposed rules for cyber incident reporting in critical infrastructure
On March 27, 2024, the Cybersecurity and Infrastructure Security Agency (“CISA”) published a Notice of Proposed Rulemaking for the Cyber Incident Reporting for Critical Infrastructure Act of 2022 (“CIRCIA”), which imposes new reporting requirements for entities operating in critical infrastructure…
NYDFS issues significant guidance on insurers using AI or external data
On January 17, 2024 the New York Department of Financial Services (“NYDFS”) published a Proposed Insurance Circular Letter (“Proposed Circular”) regarding the use of artificial intelligence systems (“AIS”) and external consumer data and information sources (“ECDIS”) in insurance underwriting and…
FCC adopts updated data breach notification rules to protect consumers
On December 13, 2023, the Federal Communications Commission (FCC) voted to update a 16-year-old privacy rule expanding breach notification requirements for telecommunications, interconnected Voice over Internet Protocol (VoIP), and telecommunications relay services (TRS). Under the new rule, these companies are…
NYDFS releases major update to Part 500 cybersecurity requirements for financial services companies
On November 1, 2023, the New York Department of Financial Services (“NYDFS”) released the finalized amendments of Part 500 of its cybersecurity regulations. These revisions represent the most significant modifications since the enactment of the rules in March 2017. Noticeably…
FTC amendment to Safeguards Rule
Under the Federal Trade Commission’s (“FTC”) new amendment to the Safeguards Rule (the “Amended Rule”), non-banking financial institutions will have to report certain data breaches and other security events to the agency.
Requirements
Approved on October 27, 2023 by a…
NIST Proposes Revised Security Guidelines For Federal Contractors
In response to the constantly evolving landscape of cybersecurity threats, the National Institute of Standards and Technology (NIST) has recently updated their guidelines for Special Publication NIST 800-171, making its guidance more prescriptive, and potentially making it harder for contractors…
NYDFS proposes significant cybersecurity regulation amendments
On November 9, 2022, the New York Department of Financial Services (NYDFS) officially proposed changes to its cybersecurity regulation and opened a 60-day public comment period. NYDFS had issued a “pre-proposed” version of the changes in July of this year…
CISA Releases New Infrastructure Cybersecurity Goals for Critical Infrastructure
On October 27, 2022, the Cybersecurity & Infrastructure Security Agency (“CISA”), in partnership with the National Institute of Standards and Technology (“NIST”) and the interagency community, published the first iteration of its cross-sector Cybersecurity Performance Goals (“CPGs”). Drafted in response…