SEC
Yesterday’s SEC release alleging that software developer SolarWinds Corp. and its Chief Information Security Officer (CISO) T. Brown misled investors about known cybersecurity risks and vulnerabilities is yet another in a series of Commission actions regarding cybersecurity that should be setting off alarms for CISOs, CIOs, and the boards at all publicly traded companies and…
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This is the second blog in an ongoing series examining the often-overlooked nuances of data controller/data processor contracts. Regulatory alignment is one of the primary reasons regulations require contracts between data controllers and data processors. And, yet, despite its primacy, many contracts make the mistake of establishing this linkage with an overly simplistic clause stating…
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Segregation of Duties (SODs), a.k.a. Separation of Duties, is the basic fiduciary mechanism that prevents an individual or department from having full custody of process integrity where there is an inherent conflict of interest or an opportunity for fraud. As the name denotes, to mitigate these potential problems, the duties related to those processes are…
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A series of recent Security and Exchange Commission (SEC) announcements point to the increasing risk of whistleblowers stemming from improper IT asset disposal (ITAD) practices. First, over the past year, the SEC has issued a number of statements and proposals indicating its intentions to hold organizations (and boards) under its jurisdiction accountable for cybersecurity. At…
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On March 9, 2023, the Securities and Exchange Commission (SEC) reached a $3 million settlement with Blackbaud–a client relationship management (CRM) service provider–reflecting two trends in SEC’s enforcements which data controllers and data processors should watch. Trend #1: The enforcement action is the most recent in a series of SEC settlements for matters NOT being…
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A March 15 proposal by the Security and Exchange Commission (SEC) to amend the Gramm-Leach-Bliley Act Safeguard’s Rule will require financial institutions and their data processors (i.e., secure shredders, ITADs, managed service providers, etc.) to seriously rethink and retool their data protection contracts, recordkeeping, and policies and procedures. Here’s What it Looks Like The proposal…
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The Oxford dictionary defines Cybersecurity as “the state of being protected against the criminal or unauthorized use of electronic data, or the measures taken to achieve this.” Hard to argue with that; it’s succinct, clear, and broad. So, with that definition in mind, it would be hard to argue that restricting access to the hardware…
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