On October 16, 2023, the SEC’s Division of Examinations (“EXAMS”) issued its 2024 Examination Priorities (the “2024 Priorities”). The 2024 Priorities reflect the Commission’s continued scrutiny of information security and operational resiliency at registrants and the risks posed by third-party service providers, as well as new attention to artificial intelligence and other forms of so-called emerging financial technology. Information Security…
As businesses adopt Generative AI tools, they need to ensure that their governance frameworks address not only AI-specific regulations such as the forthcoming EU AI Act, but also existing regulations, including the EU and UK GDPR. In this blog post, we outline eight questions businesses may want to ask when developing or adopting new Generative AI tools or when considering…
On September 21, 2023, the Colorado Division of Insurance (the “DOI”) released its Final Governance and Risk Management Framework Requirements for Life Insurers’ Use of External Consumer Data and Information Sources, Algorithms, and Predictive Models (the “Final Regulation”). As discussed below, the Final Regulation (which becomes effective on November 14, 2023) reflects several small changes from the previous version of…
Key takeaways from August include: Conflicts of interest: Businesses should consider re-evaluating their data protection officer’s role and responsibilities, including dual roles on boards and committees, to prevent conflicts of interest arising in light of the Spanish AEPD’s €5,000 fine for related failures; Automated decision-making: Businesses need not disclose the algorithms used in automated decision-making in response to data subject access requests,…
After years of deliberation, the UK passed its long-awaited Online Safety Bill (the “OS Bill”). It imposes content moderation requirements on certain online platforms and service providers to address illegal and harmful content. The OS Bill reflects a recent trend to scrutinise online platforms’ and service providers’ operations, particularly their interaction with children. For example, the UK ICO has made…