A recent report entitled “Promoting UK Cyber Prosperity: Public-Private Cyber-Catastrophe Reinsurance” issued by Long Finance examines the potential effects of cyber-catastrophe events on the economy. The report, available here, recommends the creation of a public-private cyber-catastrophe reinsurance scheme, or an extension to the existing terrorism pool, in order to
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Theodore Augustinos
NAIC Issues 12 Principles for Insurance Regulatory Guidance on Cybersecurity
On April 16, 2015, the Cybersecurity Task Force of the National Association of Insurance Commissioners adopted 12 principles for effective cybersecurity insurance regulatory guidance. Recognizing that cybersecurity risks pose a significant threat to consumer financial and health information, as highlighted by recent, significant data breaches, the NAIC took steps to…
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Attention, Health Insurers: Unique Encryption Requirements in NJ
As further analyzed in our QuickStudy, available here, New Jersey has enacted a new law (P.L. 2014, c. 88, codified at N.J. Stat. Ann. §§ 56:8-196 – 56:8-198) effective August 1, 2015, requiring health insurance carriers authorized to issue health benefit plans in New Jersey to encrypt personal information…
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NY DFS Announces New Focus on Cyber Threat in Bank Exams
The NY State Department of Financial Services has announced new IT examination procedures for banks chartered or licensed in NYS to focus on cyber security. The announcement, found here, sets out areas of focus in upcoming examinations, including written policies and procedures, intrusion protection, information security testing (including penetration…
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Update: CT Captive Insurance Amendments Effective October 1, 2014
An act amending the Connecticut captive statute pursuant to Public Act No. 14-6 (the “Act”), reported here, has been signed by Connecticut Governor Dannel P. Malloy, and will take effect October 1, 2014. …
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CFPB’s Proposed Amendment to Regulation P Would Allow Financial Institutions That Limit Data-Sharing to Post Annual GLB Privacy Notices Online
On May 6, 2014, the Consumer Financial Protection Bureau (the “CFPB”) proposed an amendment to Regulation P (the “Proposed Amendment”) that would allow financial institutions that do not engage in certain types of information-sharing to largely cease mailing the annual consumer privacy notices required by the Gramm-Leach Bliley Act (“GLB”) if they post their privacy notices on their websites and meet certain other conditions. …
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CA Update: Sponsors Drop Privacy Ballot Initiative
According to media reports, sponsors of a ballot initiative to add significant privacy rights to the California constitution, as reported here, have now dropped the initiative. …
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CA Residents to Decide on Constitutional Privacy Rights
More major privacy and data protection developments are in the works in California, following three significant new laws reported here. On September 25, 2013, the California Secretary of State approved steps required to bring before state residents a ballot initiative entitled the Personal Privacy Protection Act (the “Act”). …
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California Extends Breach Notification Obligations to Online Account Credentials
A new amendment to California’s breach notification statutes extend notification requirements to the breach of California residents’ online account credentials, with distinctive obligations regarding method and content of such notices. …
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Employer-Sponsored Health Plans and SEPT. 23 HIPAA DEADLINE: Time for a Tune Up?
Self-insured employer health plans, whether administered by the sponsor or by a third party administrator (TPA), need to be in compliance with the amended HIPAA rules, effective September 23, 2013. That date has now passed and not all employers with self-insured plans are aware of their obligations or have fully complied. …
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