BreachExchange mailing list archives
SEC Regulation S-P: Privacy of Consumer Financial Information and Safeguarding Personal Information
From: "Mark Simon" <msimon2 () eclipsecurityllc com>
Date: Wed, 12 Mar 2008 11:30:50 -0500
Terry- Thanks for calling to our attention proposed amendments to SEC Regulation S-P: Privacy of Consumer Financial Information and Safeguarding Personal Information. I have some additional information I'd like to add to your posting. The SEC is seeking comments on its proposed amendments at http://www.sec.gov/cgi-bin/ruling-comments?ruling=s70608&rule_path=/comm ents/s7-06-08&file_num=S7-06-08&action=Show_Form&title=Part%20248%20-%20 Regulation%20S-P:%20Privacy%20of%20Consumer%20Financial%20Information%20 and%20Safeguarding%20Personal%20Information The amendments are expected to affect more than 17,000 covered institutions. The proposal is at http://www.sec.gov/rules/proposed/2008/34-57427.pdf Prompting the proposal is the following finding by the SEC: "We have become concerned with the significant increase in the number of information security breaches that have come to light in recent years and the potential created by such breaches for misuse of personal financial information, including identity theft. We are concerned that some firms do not regularly reevaluate and update their safeguarding programs to deal with increasingly sophisticated methods of attack. To help prevent and address security breaches at covered institutions, we propose to require more specific standards for safeguarding personal information, including standards for responding to data security breaches." The SEC has yet to publish its proposed regulatory amendments in the Federal Register. Once publication occurs, there will be a 60-day comment period. The regulation amendments could take effect shortly thereafter. -- Mark S. Simon, Director of Regulatory Compliance Consulting Eclipsecurity, LLC Mobile: (224) 612-3101 Office: (847) 850-5088 Toll Free: (877) 369-5331 www.eclipsecurityLLC.com Lock-in success. Because information travels... The information contained in this message may be CONFIDENTIAL and is for the intended addressee only. Any unauthorized use, dissemination of the information or copying of this message is prohibited. If you are not the intended addressee, please notify the sender immediately and delete this message. -----Original Message----- From: dataloss-bounces () attrition org [mailto:dataloss-bounces () attrition org] On Behalf Of Miller, Terry Sent: Wednesday, March 12, 2008 9:16 AM To: Rob Shavell; dataloss () attrition org Subject: Re: [Dataloss] A data security breach legislation question Note that on March 4 the SEC proposed expanding privacy Regulation S-P which is based on GLBA. The proposed expansion, which is based in large part on existing banking and FTC regulations, would include a national notification requirement. The requirement may preempt certain state laws which allow for such preemption. Here is the proposal, which is now out for comment. http://www.sec.gov/rules/proposed/2008/34-57427.pdf Terry -----Original Message----- From: dataloss-bounces () attrition org [mailto:dataloss-bounces () attrition org] On Behalf Of Rob Shavell Sent: Wednesday, March 12, 2008 8:30 AM To: dataloss () attrition org Subject: Re: [Dataloss] A data security breach legislation question hi all, the question i have around US data breach notification legislation is this: "why are we counting states?" if most legislation applies to affected record-holders if they are residents and 95% of breaches already either happen in a state with a law or include records of persons residing in such states, then... hasn't this basically become a necessity? in other words, organizations had better just notify to be in compliance. following from this: what is the importance to an organization of reading through particulars of state by state legislation when they can just follow California, notify everyone, and be in compliance? bonus question: in your opinion, why are so many companies choosing to include credit monitoring services for those affected? a) altruism b) just not that costly c) concern about downstream law-suits d) ? rgds, rob On 10/03/2008, Susan Orr <susan () susanorrconsulting com> wrote:
I was just looking at the various states the other day, and there are
some differences - some exempt encrypted information, some exclude financial institutions and others that are covered under other
existing
federal and state laws like GLBA. One state I believe exempts "state
agencies" Oklahoma I think. Didn't know it was up to 40, last I saw was 38. I'll have to check
it
out, thanks. Rebecca Herold wrote: > Counting the District of Columbia, as of the end of October it was
40; see
>
http://www.privacyguidance.com/files/statebreachnotificationlaws10.19.07 .pdf
> > Best regards, > > Rebecca Herold > ----- Original Message ----- > From: "Kalter, Sarah " <skalter () affiniongroup com> > To: "lyger" <lyger () attrition org>; <dataloss () attrition org> > Sent: Monday, March
10, 2008 10:07 AM > Subject: [Dataloss] A data security breach legislation question > > > >> Hi All, >> >> Does anyone happen to know how many states have enacted data
security
>> breach laws/legislation? And if so, which states? >> >> Thank you so much! >> >> Best, >> Sarah >> _______________________________________________ >> Dataloss Mailing List (dataloss () attrition org) >> http://attrition.org/dataloss >> >> Tenable Network Security offers data leakage and compliance
monitoring
>> solutions for large and small networks. Scan your network and
monitor your
>> traffic to find the data needing protection before it leaks out! >> http://www.tenablesecurity.com/products/compliance.shtml >> > > _______________________________________________ > Dataloss Mailing List (dataloss () attrition org) > http://attrition.org/dataloss > > Tenable Network Security offers data leakage and compliance
monitoring
> solutions for large and small networks. Scan your network and
monitor your
> traffic to find the data needing protection before it leaks out! > http://www.tenablesecurity.com/products/compliance.shtml > _______________________________________________ Dataloss Mailing List (dataloss () attrition org) http://attrition.org/dataloss Tenable Network Security offers data leakage and compliance
monitoring
solutions for large and small networks. Scan your network and monitor
your
traffic to find the data needing protection before it leaks out! http://www.tenablesecurity.com/products/compliance.shtml
_______________________________________________ Dataloss Mailing List (dataloss () attrition org) http://attrition.org/dataloss Tenable Network Security offers data leakage and compliance monitoring solutions for large and small networks. Scan your network and monitor your traffic to find the data needing protection before it leaks out! http://www.tenablesecurity.com/products/compliance.shtml This email, including attachments, may include confidential and/or proprietary information, and may be used only by the person or entity to which it is addressed. If the reader of this email is not the intended recipient or his or her authorized agent, the reader is hereby notified that any dissemination, distribution or copying of this email is prohibited. If you have received this email in error, please notify the sender by replying to this message and delete this email immediately. _______________________________________________ Dataloss Mailing List (dataloss () attrition org) http://attrition.org/dataloss Tenable Network Security offers data leakage and compliance monitoring solutions for large and small networks. Scan your network and monitor your traffic to find the data needing protection before it leaks out! http://www.tenablesecurity.com/products/compliance.shtml _______________________________________________ Dataloss Mailing List (dataloss () attrition org) http://attrition.org/dataloss Tenable Network Security offers data leakage and compliance monitoring solutions for large and small networks. Scan your network and monitor your traffic to find the data needing protection before it leaks out! http://www.tenablesecurity.com/products/compliance.shtml
Current thread:
- Re: A data security breach legislation question, (continued)
- Re: A data security breach legislation question Adam Shostack (Mar 10)
- Message not available
- Re: A data security breach legislation question Al Mac Wheel (Mar 10)
- Re: A data security breach legislation question Anthony Franks (Mar 10)
- Re: A data security breach legislation question Mike Simon (Mar 10)
- Re: A data security breach legislation question Rebecca Herold (Mar 10)
- Re: A data security breach legislation question Privacy Laws (Mar 10)
- Re: A data security breach legislation question Rebecca Herold (Mar 10)
- Re: A data security breach legislation question Susan Orr (Mar 10)
- Re: A data security breach legislation question Rob Shavell (Mar 12)
- Re: A data security breach legislation question Miller, Terry (Mar 12)
- SEC Regulation S-P: Privacy of Consumer Financial Information and Safeguarding Personal Information Mark Simon (Mar 12)
- Re: SEC Regulation S-P: Privacy of Consumer Financial Information and Safeguarding Personal Information Miller, Terry (Mar 12)
- Re: A data security breach legislation question Rebecca Herold (Mar 12)
- Re: A data security breach legislation question Craig Muller (Mar 12)
- Re: A data security breach legislation question Michael Hill, CITRMS (Mar 12)
- Re: A data security breach legislation question Beth Givens (Mar 12)
- Re: A data security breach legislation question Peyton, Janet P. (Mar 12)
- Re: A data security breach legislation question Chris Walsh (Mar 12)