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The Cloud Grounded: Cloud Hosts Are Business Associates Under HIPAA Security Rule

Posted in Data Security, Health Information, Other

The Department of Health and Human Services Office for Civil Rights (OCR) issued long-anticipated guidance to help covered entities and their business associates — including cloud service providers (CSPs) — comply with the Health Insurance Portability and Accountability Act (HIPAA) … Continue Reading

Vizio and Google Data Privacy Class Actions Illustrate Risks of Data Collection – And Defensive Value of Robust Disclosures

Posted in Consumer Privacy/FTC, Litigation, Other

Two recent developments in data privacy litigation highlight the continuing challenges to companies that collect internet usage information without clearly disclosing the manner and method in which they are doing so to users.  As these events demonstrate, plaintiffs’ attorneys are … Continue Reading

Class Action Exposes Massive Data Leak Of Social Security and Drivers’ License Numbers of Every Registered Georgia Voter; Secretary of State Admits “Clerical Error”

Posted in Data breach, Litigation, Other

Did the Georgia Secretary of State release the social security numbers, driver’s license numbers, and dates of birth of every registered Georgia voter?  Those are the allegations first made by putative class representatives, Elise Piper and Yvette Sanders, in a … Continue Reading

White House Proposes Expansive Data Breach Notification Bill

Posted in Consumer Privacy/FTC, Data breach, Financial Services Information Management, FTC enforcement, Legislation, Other

Last week, President Obama proposed wide-reaching legislation to establish a uniform, nationwide standard for data breach notifications that envisions a significant enforcement role for the Consumer Financial Protection Bureau (CFPB). The proposal, titled the Personal Data Notification and Protection Act, … Continue Reading

Treasury: Ten Questions for Bank Executives and Boards of Directors

Posted in Data retention, Financial Services Information Management, Information Management, Other

On December 3, 2014, Sarah Raskin, Deputy Secretary of the U.S. Department of Treasury (Treasury), gave a speech before the Texas Banker’s Association Executive Leadership Cybersecurity Conference. Deputy Secretary Raskin’s remarks provide effective guidance for community bank chief executive officers, … Continue Reading