How to Respond to Automated Data Subject Requests

The implementation of high-profile data laws such as the EU’s General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA) have given consumers the ability to exercise previously-unheard-of rights.  This paradigm shift has left businesses and financial organizations scrambling to keep up, perhaps most notably with data access and opt-out requests–when consumers submit…
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A Guide to FINRA’s 2021 Compliance Goals

The Financial Industry Regulatory Authority (FINRA) recently published their 2021 Report on FINRA’s Examination and Risk Monitoring Program. The report contains insights for FINRA’s regulatory operations and is designed to guide the compliance efforts of member firms. In the broadest sense, FINRA declares cybersecurity as “one of the principal operational risks facing broker-dealers,” expecting firms…
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EU Releases Draft Decision on UK Data Privacy Standards

Since the start of 2021, post-Brexit data relationships between the European Union and the United Kingdom have been governed by The EU-UK Trade and Cooperation Agreement, which established a 4-6 month temporary period where data could flow freely between the two jurisdictions.  Beyond that, the future was unclear. The grace period could have been extended…
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Virginia Set to Enact Major Data Privacy Legislation

Of all the states currently in the process of enacting major privacy legislation, Virginia may be closest to the finish line. On February 5, the Senate of Virginia voted unanimously to approve the Consumer Data Protection Act (CDPA), with the House of Delegates voting 89-9 to approve an identical bill.  Minor amendments are expected after the…
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The Washington Privacy Act is Back in Play

It’s been a turbulent journey for the Washington Privacy Act (WPA). When initially proposed in 2019, the legislation seemed like Washington’s answer to the California Consumer Privacy Act (CCPA), establishing a stricter approach to state-level data privacy. However, the bill narrowly failed to pass in 2019, meeting the same fate when reworked in 2020. Though…
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2020 News in Review

Week Ending December 28  ICO Warns SolarWinds Victims to Report Breaches  The United Kingdom’s Information Commissioner’s Office (ICO) has issued a warning to organizations compromised by the SolarWinds breach. The breach, which was carried out by Russian hackers, affected more than 18000 organizations worldwide. ICO requires UK data controllers subject to NIS regulations to report…
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ADCG Launches Data Privacy Law Comparison Tool

In 2018, the European Union launched its landmark data privacy law, the General Data Protection Regulation (GDPR). What followed can only be described as a wave of data privacy laws that swept the globe. Legislators from California to Brazil, to New Zealand have passed some form of data privacy law with the potential to impact…
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Does Your Organization Need A Chief Privacy Officer

Does Your Organization Need a Chief Privacy Officer?

As the presence of global data privacy legislation continues to rise, so does the importance of privacy-related positions. The EU’s General Data Protection Regulation (GDPR) mandates that companies hire a Data Protection Officer, and related roles like Chief Information Security Officer (CISO) have also become more valued. One of the most concrete action items a…
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New Zealand’s Data Privacy Law Now Effective

On December 1, New Zealand’s new data privacy law took effect.  The Privacy Act 2020 impacts every organization with a physical or virtual presence in New Zealand. Any offshore organization that collects data from New Zealanders must comply.  This marks the suspension of 1993’s Privacy Act and puts the pressure on organizations to handle data…
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