Colin H. Black

Nov 14, 2023 | jdsupra.com | Colin H. Black |Alexander B. Boyd

On October 27, 2023, the Federal Trade Commission (“FTC”) adopted an amendment to the FTC’s Safeguards Rule that will require non-banking financial institutions to notify the FTC within thirty days of discovering a data breach involving the nonpublic personal information of at least 500 consumers. The amendment takes effect 180 days after publication in the Federal Register, which suggests an effective date in mid-2024.

May 23, 2023 | natlawreview.com | Colin H. Black

Effective June 9, 2023, the Federal Trade Commission’s (FTC) updated enacting regulations to the Gramm-Leach-Bliley Act (GLBA) Safeguards Rule will take effect. The updates to the regulations include more robust privacy and security requirements for financial institutions that are primarily regulated by the FTC. By this date, among other things, relevant organizations must have implemented an information security program that incorporates nine specific elements.

Jan 18, 2023 | natlawreview.com | Colin H. Black

Wednesday, January 18, 2023 The continued proliferation of tracking technologies has created a landscape of increased exposure for entities serving individuals online. As individuals are increasingly interacting with healthcare services providers online, the Department of Health & Human Services (“HHS”) Office for Civil Rights (“OCR”) has issued new guidance for regulated entities to address privacy concerns stemming from the use of tracking technologies.