On March 15, 2024, Erez Liebermann, Caroline Swett, Robert Maddox, and Stephanie Thomas from our Data Strategy and Security and Banking Groups hosted the next installment of our Data Security Webcast, where they delved into the Commodity Futures Trading Commission’s (“CFTC”) notice of proposed rulemaking for an operational resilience framework for futures commission merchants, swap dealers, and major swap participants…
In July, we previewed the new rules adopted by the Securities and Exchange Commission (“SEC”) for Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure. Under these rules, Item 1.05 of Form 8-K requires U.S. public companies to disclose material cybersecurity incidents. We have been tracking Form 8-K filings under the new SEC requirements since the rules went into effect on…
On February 28, 2024, President Biden issued an Executive Order (the “Order”) designed to protect the “sensitive personal data” of Americans from “exploitation” by “countries of concern” or related “covered persons.” Concurrently, the Department of Justice (“DOJ”) released an Advance Notice of Proposed Rulemaking (“Advance Notice”), detailing potential definitions for key terms not defined in the Order, discussing the potential…
Key takeaways from January include: Transparency about data processing and retention: In a reminder of the importance of transparency under the GDPR, and the need for companies to make their data subject access request processes easy to navigate, the Dutch data protection authority fined Uber €10 million for, amongst other failings: (i) not specifying to drivers how long it retained…
On 18 March 2024, Avi Gesser and Martha Hirst from the Debevoise Data Strategy and Security Group, in conjunction with the AI UK 2024 symposium, presented on the regulatory developments, and associated governance risks, relating to AI use. The presentation included practical guidance that can support businesses’ ability to use AI agilely within a developing regulatory landscape. The proliferation of…