On April 16, the Securities and Exchange Commission (SEC)’s Office of Compliance Inspections and Examinations (OCIE) released a new Risk Alert that identifies common compliance issues
Continue Reading OCIE Issues Risk Alert Regarding Compliance With Regulation S-P’s Notice and Safeguard Policy Requirements
The Security and Exchange Commission’s Office of Compliance Inspections and Examinations (OCIE) recently released an initial summary of its findings from its 2014 OCIE Cybersecurity Initiative. The OCIE examined
Continue Reading SEC and FINRA Examine Cybersecurity
SAIC’s recent Motion to Dismiss the Consolidated Amended Complaint filed in federal court in Florida as a putative class action highlights the gaps between an incident (like a theft) involving PHI, a determination that a breach of PHI has occurred, and the realization of harm resulting from the breach.
Continue Reading The SAIC Breach and a Look Across the Chasm Between Significant Risk and Actual Harm Resulting from a HIPAA Breach