Tag Archives: Information

IRS Warns of “Surge” in Tax Season Phishing Scams

tax iconTax season ‘tis the season to be phishing, according to the IRS.  The IRS has issued a warning to payroll and human resources professionals about a “surge” in phishing emails seen this year.  One of the preferred tactics of identity thieves this year appears to be impersonating CEOs and sending emails to company payroll and human resources departments asking for employee W-2s.  The employees think they… More

European Union Agrees On a New Data Protection Framework To Replace the 95/46/CE Directive: Meet the “General Data Protection Regulation”

On 15 December 2015, the three main European institutions, the Commission, the Parliament and the Council, agreed on the final text of the General Data Protection Regulation (GDPR) which has been on the table since January 2012. This is a major achievement, given the number of obstacles that still needed to be overcome a few weeks ago in order to meet the end of 2015 deadline for finalizing the GDPR.  The GDPR provides a brand new single set of rules for the protection of data within the whole Europe and these rules are very different from those enshrined… More

CFTC Approves NFA Interpretive Notice on Information Systems Security Programs, Including Cybersecurity Guidance

By Catherine M. Anderson and Kate Leonard

The CFTC recently approved the National Futures Association’s interpretive notice (the “Cybersecurity Notice”) on the general requirements that members should implement for their information systems security programs (“ISSPs”), which includes cybersecurity guidance and ongoing testing and training obligations.

The Cybersecurity Notice will be effective March 1, 2016 and applies to futures commissions merchants, commodity trading advisors, commodity pool operators, introducing brokers, retail foreign exchange dealers, swap dealers, and major swap participants (each, a “Member”). The Cybersecurity Notice emphasizes that the exact form of an ISSP should be adopted and tailored to… More

Cybersecurity and Information Sharing Act Clears Senate Hurdle; House Action Unclear

The Cybersecurity and Information Sharing Act (S.754), or CISA, cleared an important hurdle on Thursday when the Senate voted 83-14 to end debate on several amendments to the bill.  CISA creates a cyberthreat information sharing system to, in the words of the bill, “improve cybersecurity in the United States.”  Specifically, as currently drafted, the bill requires various government actors and agencies (such as the Attorney General and the Department of Homeland Security) to create specific policies and regulations relating to the sharing… More

Update on President Obama’s “Summit on Cybersecurity and Consumer Protection,” Part III: Five Key Lessons for Business

Concluding our three-part analysis of the White House’s first Summit on Cybersecurity and Consumer Protection, we turn to some practical advice coming out of the Summit’s afternoon session, including an address by Maria Contreras-Sweet, the administrator of the Small Business Administration (“SBA”), and a panel discussion among financial sector leaders moderated by Deputy Treasury Secretary Sarah Bloom Raskin.

Here are five takeaways for companies large and small:

Companies are only as secure as their most vulnerable employee. In the course of the panel discussion, Mike George, CEO of QVC, elaborated on how training and constant vigilance were at the… More

SEC Hosts Cybersecurity Roundtable

Cybersecurity remains a hot topic for regulators, including the Securities and Exchange Commission (SEC).  On March 26, 2014, the SEC hosted a roundtable to discuss cybersecurity and the issues and challenges it raises for market participants.  The roundtable addressed cybersecurity concerns for investment advisers, broker-dealers and public companies, and provided a forum to share information as to how they are addressing those challenges. This roundtable follows hard on the heels of the Financial Industry Regulatory Authority (FINRA) sending targeted sweep letters in January-February 2014 to broker-dealers querying their approaches to managing cybersecurity risks.

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Survey Reveals Generation Gap in Employee Attitudes Toward Confidential Information

A recent Harris Interactive survey of 2,625 adult Americans reveals some interesting attitudes towards employer confidential information, including significant variations depending on an employee’s age:

– 68% of 18-34 year olds responded that it is acceptable to remove confidential information from their place of employment. This contrasts with just half (50%) of those 55 years old or older believing such behavior is acceptable.

– 86% of those 55 years old and over believe someone should be fired for taking confidential information, while 74% of those younger than 55 years old think the same.

– 40% of adults believe it… More

Breaking Down the White House Privacy Framework–a Video Blog

Here is a video discussion I had with LexBlog on the new White House Data Privacy report, “Consumer Data Privacy in a Networked World: A Framework for Protecting Privacy and Promoting Innovation in the Global Digital Economy.” In this conversation, we discussed the report’s four primary elements:

a Consumer Privacy Bill of Rights, a multistakeholder process to specify how the principles in the Consumer Privacy Bill of Rights apply in particular business contexts, effective enforcement, and a commitment to increase interoperability with the privacy frameworks of our international partners.

Specifically, in the Consumer Privacy Bill of Rights,… More

Most Recent Sony Breach Illustrates the Cascading Effect of Data Breaches

It was revealed recently that Sony’s on-line services were the subject of another significant attack. This incident, however, did not exploit a vulnerability in Sony’s security infrastructure so much as it highlighted the cascading effect of data breaches.

Rather than try to scale any fences or jimmy any windows, this attack used account holders’ own keys to open the front door. According to a statement by Sony, the attackers tested a “massive set” of log-in credentials, consisting of pairs of user IDs and passwords, against accounts on three of its networks. Even though the “overwhelming majority” of the log-in attempts failed,… More