NYDFS Releases Pre-Proposed Second Amendment to its Cybersecurity Regulations, 23 NYCRR 500

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On July 29, 2022, the New York Department of Financial Services (NYDFS) published the pre-proposed second amendment to its Cybersecurity Regulations, 23 NYCRR 500 (Part 500), that if adopted, would likely require numerous policy and operational changes. NYDFS sought comments to the pre-proposal through August 18, 2022. Although this amendment has been long-anticipated, the next step will be for NYDFS to formally publish the second amendment.

Effective in 2017, Part 500 was a first-of-its-kind state regulation that created mandatory cybersecurity and risk management regulations for “covered entities.” Part 500 defines Covered Entities as persons operating under or required to operate under a license, registration, charter, certificate, permit, accreditation or similar authorization under the Banking Law, the Insurance Law or the Financial Services Law.

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Log4j Vulnerability Prompts Insurance Commissioners to Issue Guidance

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On December 11, 2021, the Cybersecurity and Infrastructure Security Agency, in partnership with the FBI and NSA, announced a critical remote code execution vulnerability had been identified in the Apache Log4j software library. This vulnerability allowed a successful threat actor to take control of a network system and cause a variety of damage, including the ability to launch ransomware, steal and destroy victim information, deploy malware, and disrupt internal and infrastructure operational control. Insurance regulators from four states have recently issued guidance in response to the threat, and it is likely more insurance commissioners will follow suit.

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COVID-19 Consumer Data Protection Act of 2020 Seeks to Regulate Collection, Use of Geolocation, Personal Health Information

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Contact tracing is recognized by health systems and governments as an effective method to identify individuals an infected person may have exposed to disease in order to notify those individuals and take action to prevent further spread of illness. Traditionally, the accuracy of contact tracing has been dependent upon an individual’s memory of (and willingness to disclose) where they have been and with whom they have been in contact in order to track down other people who may have been infected. Connected devices with geolocation capabilities allow for digital tracking of individuals, but also carries significant privacy issues.

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