On April 3 , Alston & Bird Senior Associate Michael Young issued a Client Alert on a recent announcement made by the Federal Trade Commission on proposed rule updates to two key privacy and security regulations of the Safeguards Rule and the Privacy Rule that address new cybersecurity requirements. The Client Alert provides key highlights of the proposed rule updates for both rules as follows. Under the Safeguards Rule, the proposal seeks to partially model itself after New York’s Cybersecurity Regulations, and would include a number of information security requirements. Under the Privacy Rule, the proposal seeks to update the Privacy Rule to address annual privacy notice requirements. In addition, the proposal seeks to provide clarification of the limited scope of the rulemaking authority of the FTC under Gramm Leach Bliley. The Client Alert also points out that the requirements set forth in the proposals may significantly impact various entities in the financial services industry and its activities under the authority of the FTC.
The Client Alert can be found here on the Alston & Bird Privacy Blog.