On April 30, 2026, the New York Department of Financial Services (NYDFS) announced a consent order with Delta Dental Insurance Company and Delta Dental of New York, Inc. for alleged violations of the NYDFS Cybersecurity Regulation relating to the 2023
over-retention
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…
Regulators, including FCC, emphasize third party vendor cybersecurity monitoring requirements
Many data breaches occur not at the company that controls or owns the data, but rather at the company’s third-party service providers or vendors. Regulators have noticed and have begun placing emphasis on a company’s obligation to monitor its service…
NYDFS fines licensee $2 million for lack of email retention policy and MFA
On August 14, 2025, the New York Department of Financial Services (“NYDFS”) entered into a consent order with Healthplex, Inc, (“Healthplex”), which is licensed by NYDFS as an independent claims adjuster and as a life and/or accident health insurance agent. …
New York hospitals have new cybersecurity requirements
On October 2, 2024, the New York State Department of Health (DOH) published a new cybersecurity regulation (10 NYCRR 405.46) for all general hospitals licensed pursuant to article 28 of the Public Health Law. Although most of the regulation will…
New York Department of Financial Services addresses cybersecurity risks from artificial intelligence



On October 16, 2024, the New York Department of Financial Services (“NYDFS” or “DFS”) issued guidance raising awareness about combatting cybersecurity risks arising from artificial intelligence (“AI”) used by DFS licensees, such as insurers and virtual currency businesses. Risks revolve…
California Attorney General and data security, access and retention
Two FTC complaints that over-retention of personal data violates Section 5

On January 18, 2024, the U.S. Federal Trade Commission announced a complaint and proposed consent order with InMarket Media, LLC, a digital marketing platform and data aggregator. Less than two weeks later, on February 1, the FTC announced a complaint…
$8 million penalty to NYDFS – and another case of over-retention

2024 was not a happy new year for Genesis Global Trading, Inc. (“GGT”). On January 3, 2024, the New York Department of Financial Services announced a consent order with GGT, where GGT agreed to pay NYDFS $8 million and to…
NYDFS settles with EyeMed for $4.5 million

On October 18, 2022, the New York Department of Financial Services announced a settlement with EyeMed, a licensed life, accident, and health insurer, with respect to a security incident that occurred in 2020. The settlement claimed that EyeMed had committed…




