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Gertrūda Valasevičiūtė, Unsplash

On March 7, 2025, the Department of Homeland Security (“DHS,” “the agency”) disbanded the Critical Infrastructure Partnership Advisory Council (“CIPAC,” “the Council”), originally established in 2006 to facilitate communication between the public and private sectors on critical infrastructure issues. CIPAC’s termination comes against the backdrop of the 2015 Cybersecurity Information Sharing Act’s (“CISA 2015,” “the Act”) upcoming expiration on September 30, 2025. CIPAC and CISA 2015 have jointly provided a valuable legal and operational framework for sharing information between the public and private sector in the U.S. for the past decade. Financial services industry stakeholders and members of Congress have expressed concern in recent months over increased cyber threats to industry stakeholders should the current public-private information sharing framework deteriorate. These recent developments are poised to significantly impact the financial services industry’s cybersecurity landscape – absent steps by Congress and the Administration to provide continuity for the current framework. Continue Reading CIPAC Disbandment and CISA 2015 Reauthorization: Recent Developments in the U.S. Cybersecurity Landscape

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In an International Association of Privacy Professionals (IAPP) article, health care partner David Peloquin and data, privacy and cybersecurity associate Jake Barr along with Legend Biotech Chief Privacy Officer and Assistant General Counsel Corey Dennis discuss the landmark rule limiting sensitive data transfers to “countries of concern.” The article reviews key aspects for health care…

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In 2024, financial sector regulators prioritized cybersecurity issues impacting financial institutions and the public. Key U.S. federal agencies—including the Securities and Exchange Commission, Federal Trade Commission, and the Consumer Financial Protection Bureau—have been joined by state regulators such as the New York Department of Financial Services in significant new federal and state regulations and more…

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In December 2024, New York Governor Kathy Hochul signed into law two bills (A8872A and S2376B; collectively, the “Bills”) that amend New York’s Data Breach Notification Law.1 The Bills introduce a maximum thirty-day timeframe for notifying affected New York residents of a reportable “breach of the security of the system”2 under…

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On October 22, 2024, the Securities and Exchange Commission (“SEC”) filed settled enforcement orders involving four current and former public companies – Unisys Corp., Avaya Holdings Corp., Check Point Software Ltd, and Mimecast Limited. The settlements concern the issuers’ disclosures relating to cybersecurity risks and intrusions following the December 2020 SUNBURST cybersecurity incident, which affected…

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On May 15, 2024, the New York State Department of Health (“NYSDOH”) published revisions to the proposed hospital cybersecurity regulations that it first released in November 2023. Most of the requirements of the initially proposed regulations have been retained in the revised version, subject to a few modifications. The revised proposed regulations are subject to…

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In a Bloomberg Law article, attorneys examined Washington State’s comprehensive new privacy law, the My Health My Data Act, the first state law that specifically safeguards consumer health data.

The article discusses the new law’s scope, applicability, and ensuing company obligations. The Act will apply to many life sciences companies, pharmaceutical and device…

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On February 9, 2024, a California state court of appeal unanimously vacated a lower court ruling, green-lighting the California Privacy Protection Agency’s authority to commence enforcement of the Agency’s first set of regulations. Until now, the Agency’s authority to enforce regulations it has promulgated under the California Consumer Privacy Act (“CCPA”) has been delayed. The Agency had been poised to begin enforcing its latest batch of completed privacy regulations on July 1, 2023, but a trial court’s ruling put this work on hold until March 29, 2024. That hold has now evaporated, and so the Agency can commence enforcement activities with immediate effect. The decision also impacts future Agency rulemaking such as the Agency’s draft regulations on cybersecurity audits, privacy impact assessments, and automated decision-making, which will no longer be subject to the 12-month stay of enforcement.Continue Reading California Court of Appeal Restores CPPA Authority to Enforce Privacy Regulations

In the wake of the Supreme Court’s 2021 decision in Facebook v. Duguid—which held that most smartphones and similar modern technology do not qualify as “automated telephone dialing systems,” under the Telephone Consumer Privacy Act (TCPA)—there has been a spike in state legislative activity aimed at strengthening local telemarketing laws. Florida’s Telephone Solicitation Act (FTSA) became the first state telemarketing law of its kind on July 1, 2021. The FTSA, which does not clearly define the types of automated technology covered by the statute, creates room for a broader interpretation of the types of devices that can qualify as regulated dialing technology. Oklahoma has now become the next state to enact such legislation, the Oklahoma Telephone Solicitation Act (OTSA), which largely mimics the FTSA and came into effect on November 1, 2022.Continue Reading Oklahoma’s New Restrictive Telemarketing Law: Could Other States Be Next?