New York AG Seeks to Require Privacy Violation Notifications

While the law has adapted to the reality of cyberattacks and data breaches, in the wake of recent revelations about Facebook use of personal information, New York’s Attorney General intends to propose legislation to address Privacy Violations — where personal information is obtained or used by organizations in violation of a platform’s terms of service, or the law. Facebook has recently acknowledged that data analytics firm Cambridge Analytica collected personal information of 50 million Facebook users without their consent as part of a political influence…
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Better Late Than Never — Time to Get Those Cybersecurity Certifications of Compliance into NYDFS

If you are an individual or company regulated by the New York State Department of Financial Services (NYDFS), you may have received an email from NYDFS reminding you to submit your Certification of Compliance as soon as possible. New York’s relatively new cybersecurity regulation, 23 NYCRR 500 (the Regulation), requires all people and companies covered by the Regulation (Covered Entities) to file an annual statement by February 15 certifying that the entity was compliant (Certification of Compliance) with the Regulation as of December 31 of…
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New York’s New Cyber Law Is Beginning to Byte

In late 2016, in response to the “ever-growing threat” posed to information and financial systems, the New York State Department of Financial Services (DFS) proposed cybersecurity regulations to “promote the protection of customer information and information technology systems of regulated entities.” The DFS defined “covered entities” as any person operating under or required to operate under a license, registration, charter, certificate, permit, accreditation or similar authorization under the Banking Law, the Insurance Law, or the Financial Services Law of New York.  Banks, insurance companies, and…
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DFS Partially Clarifies Who Qualifies for an Exemption Under Cybersecurity Regulation

By the terms of 23 NYCRR 500.19(e), Covered Entities that have determined they qualify for a limited exemption from compliance under 23 NYCRR 500.19(a)-(d) of New York’s new Cybersecurity Regulation — as of August 28, 2017 — are required to file a Notice of Exemption with the New York Department of Financial Services (NYDFS) on or prior to September 28, 2017. The first compliance date of August 28, 2017 in New York’s cybersecurity regulation, and the date for Covered Entities to determine whether they qualify…
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New York Issues Final Cybersecurity Regulation

On February 13, 2017, the New York Department of Financial Services (NYDFS) adopted the final version of its first-of-its-kind cybersecurity regulation, “Cybersecurity Requirements For Financial Services Companies” (23 NYCRR 500). This regulation took effect on March 1, 2017. The final regulation reflects several of the comments offered during the final comment period that concluded on January 27, 2017. For a prior list of significant changes from the initial version to the second version, please see our blog post located here. Most of…
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