The regulatory expectation from both the SEC and the DOJ is that your firm will implement some form of a data classification system that will allow you to adequately protect your business’s sensitive information. We have previously discussed the creation and implementation of such a program. In this post we will take [...]
As we discussed in Part I of our data classification series, the regulatory expectation from both the SEC and the DOJ is that your firm will implement some form of a data classification system that will allow you to adequately protect your business’s sensitive information. In addition, a thoughtfully executed data classification system will [...]
Just weeks ago, SEC Commissioner Aguilar’s Chief of Staff noted that the SEC is about to enter “a time of great change” regarding regulation for breach disclosure. Just weeks later, the guidance from the Division of Investment Management reinforced this notion by commenting that “in the staff’s view, funds and advisers should [...]
Data Classification, Retention, and Security Part 1: What Do We Have Here? Recent SEC and DOJ guidance has placed great emphasis on Data Security through Data Classification. Regulators are expecting you to classify your information based upon criticality and sensitivity, but where do you begin? Take a minute and think about all the [...]
Legal and Financial firms should be aware of and understand the guidance offered by the U.S. Department of Justice, Criminal Division, Cybersecurity Unit, titled “Best Practices for Victim Response and Reporting of Cyber Incidents” which was issued last Friday, April 29, 2015. We sit up and pay attention when Executive Departments with [...]
The SEC has offered definitive guidance on Cybersecurity, tying failures or shortcomings in practices to specific Rules and Regulations and paving the way for potential enforcement. While we have been discussing the path the SEC was implying for some months in the wake of the Cybersecurity Sweep results of February 3, 2015, [...]
At the 2015 RSA conference, Commissioner Aguilar’s Chief of Staff, Smeta Ramarathnam, participated in a panel titled “Full Disclosure: What Companies Should Tell Investors About Cyber Incidents.” While Aguilar’s emissary reminded us of the importance of general cybersecurity risk disclosure, her message focused upon the disclosure of breach events, stating that the [...]
Evidence continues to mount for broad acceptance of NIST CSF Action Item: Executives, General Counsels, Compliance Officers, and Board Members, across industries, should consider these principles. Last week (April 17, 2015), the National Association of Insurance Commissioners (NAIC) adopted twelve basic principles to provide guidance to insurers, producers, and other regulated entities. [...]
A cybersecurity event has occurred at your firm. Your team is deep into its incident response plan. Procedures that you put in place and have tested and improved over the years are flowing relatively smoothly to their conclusion. Forensics staff have been brought in to determine how the incident occurred, law enforcement [...]
Most companies have a cybersecurity plan of sorts in place already. When we speak, in general terms, about the first three key functions in the NIST Cybersecurity Framework, “Identify”, “Detect”, and “Protect”, we are met with understanding. After all, these categories make sense to all of us. Identifying those assets that need [...]