Monthly Archives: February 2015

HIPAA Compliant Technology and the Importance of Encryption

We welcome this guest blog by Gene Fry, Compliance Officer, Scrypt, Inc.

The Health Insurance Portability and Accountability Act (HIPAA) sets the standard for protecting sensitive patient data. This means that any covered entity (CE) or business associate (BA) that deals with protected health information (PHI) must ensure that all the required physical, network, and process security measures are in place and followed. The HIPAA Privacy Rule addresses the storage,… More

Privacy Issues in Smart Electrical Grids: Another Internet of Things Problem

Smart grids – electrical grids that allow two-way communication between utilities and consumers – represent an exciting frontier in the Internet of Things, with ramifications for energy efficiency, weather resiliency and climate change, among others. As the Department of Energy writes, “[t]he Smart Grid represents an unprecedented opportunity to move the energy industry into a new era of reliability, availability, and efficiency that will contribute to our economic and environmental health.”

But like many aspects of the Internet of Things,… 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:

  1. Companies are only as secure as their most vulnerable employee.…
  2. More

Update on President Obama’s “Summit on Cybersecurity and Consumer Protection,” Part II: The Executive Order

As a follow up to our summary of the key takeaways from the White House’s first Summit on Cybersecurity and Consumer Protection, the centerpiece of which was President Obama’s signing of a new Executive Order, “Promoting Private Sector Cybersecurity Information Sharing,” what follows is an analysis of that Order.

What does the Order actually do?

The Order “promotes…encourages…and…allows” but does not require anything.… More

Update on President Obama’s “Summit on Cybersecurity and Consumer Protection,” Part I

The first ever Summit on Cybersecurity and Consumer Protection was convened today at Stanford University, keynoted by President Obama.  The purpose of the summit:  to “bring[] together major stakeholders on consumer financial protection issues to discuss how all members of our financial system can work together to further protect American consumers and their financial data.”  These stakeholders, a number of public and private sector leaders,… More

SEC Office of Compliance Inspections and Examinations Releases Cybersecurity Examination Sweep Summary of Investment Advisers and Broker-Dealers

Our colleagues Catherine M. Anderson and Kate Leonard of our Investment Management group have summarized the February 3, 2015 findings by the Office of Compliance Inspections and Examinations (OCIE) of its Cybersecurity Examination Sweep, which sought to evaluate the breadth of cybersecurity policies implemented by investment advisers (as well as by broker-dealers). For more details on the sweep, see our previous Foley Adviser update: SEC Issues Risk Alert on Cybersecurity Initiative for Investment Advisers.… More