PrivacyVirginia, Oklahoma, and Florida Join Growing List of States With Proposed Privacy Legislation

Virginia, Oklahoma, and Florida Join Growing List of States With Proposed Privacy Legislation

Since California’s Consumer Privacy Act (CCPA) was passed in 2018, Beckage has seen a slew of other states follow suit in proposing and enacting their own comprehensive data privacy bills. Most recently, lawmakers in Virginia, Oklahoma, and Florida have joined the growing list of states with proposed privacy bills. So far this year, New York, Washington, and Minnesota have also introduced legislation governing the ways companies collect, store, use, and share consumer data and we expect to see other laws emerging in the coming months with still no federal data privacy bill in sight.  

Working with experienced privacy counsel can help build out data privacy programs that stand the test of time and contemplate emerging legislation.   

Below is an overview of the Virginia and Oklahoma proposed bills, their requirements, and their potential impact on the data privacy landscape. 

Virginia Consumer Data Protection Act (SB 1392) 

The Virginia proposal is quickly moving through the Virginia state legislature and is likely to be the next comprehensive state data privacy law on the books. This bill passed the Virginia House of Delegates on January 29th by a wide margin and was unanimously approved in the Senate on February 3rd. Assuming Governor Northam signs it into law, the Virginia Consumer Data Protection Act is set to go into effect on January 1, 2023. 

Who Does It Apply To? 

Companies that conduct business in Virginia or “produce products or services that are targeted to” Virginians would have to comply with the Virginia Consumer Data Protection Act if they: 

  • Control or process the personal data of at least 100,000 Virginians; or 
  • Control or process the personal data of at least 25,000 Virginians and derive over 50% of their gross revenue from the sale of that data. 

The Legislation does provide exemptions for financial institutions governed by the Gramm-Leach-Bliley Act, entities subject to HIPAA or HITECH, non-profits, and educational institutions. 

What Is Included? 

Included in this Bill are several requirements not covered under the CCPA or any other U.S. privacy law. One such obligation requires entities that control personal data to conduct protection assessments of any activities that use personal data for specific purposes, such as targeted advertising. These data protection assessments may be requested and evaluated by the attorney general to ensure compliance. 

This Act would afford Virginia consumers with several rights regarding their personal data, including the right to opt-out of the sale or use of their information for targeted advertising or profiling. It would also allow consumers to delete their data, move their data, correct inaccuracies in their data, and confirm if their data is being processed upon request.  

Notably missing is a private right of action through which consumers could seek damages for alleged violations. Instead, enforcement of the Act would be left exclusively to the attorney general, who may seek up to $7,500 per violation. 

Oklahoma Computer Data Privacy Act (HB 1602) 

Introduced on January 19, 2021 by Representatives Josh West (R) and Collin Walke (D), this Bill has bipartisan support in the Oklahoma House of Representatives. Its intended purpose is to give Oklahomans more online privacy by taking aim at tech companies. If passed, the Oklahoma Computer Data Privacy Act would go into effect on November 1, 2021. 

Who Does It Apply To? 

If passed, this act would apply to companies that operate in the state of Oklahoma and collect Oklahoman’s personal information or have information collected on their behalf, determine the purpose for and means of processing that information, and satisfy one of the following thresholds: 

  • Has an annual gross revenue exceeding $10 million; 
  • Buys, sells, receives, or shares for commercial purposes the personal information of 50,000 or more consumers, households, or devices annually; or 
  • Derives 25% or more of their annual revenue from the sale of personal data. 

What Is Included? 

Companies subject to this legislation would be required to disclose what personal information they hold on a consumer and allow for the deletion of that information upon the consumer’s request. This proposal also mandates consumers opt-in to providing their personal data, which differentiates it from most other state privacy laws, like the CCPA. The Oklahoma Computer Data Privacy Act also differs from the CCPA in its inclusion of a broad private right of action through which Oklahoma residents could seek damages up to $7,500 for violations. 

Florida House Bill 969 (HB 969) 

Introduced on February 15th by Representative Fiona McFarland (R), House Bill 969 would place several requirements on businesses that deal with Florida residents’ private information. If passed, it would go into effect on January 1, 2022. 

Who Does It Apply To? 

For-profit companies that do business in Florida and collect personal information about consumers, have personal information collected on their behalf, or determine the process and means of processing personal information will have to comply with this Bill’s requirements if they satisfy one of the following thresholds: 

  • Has an annual gross revenue exceeding $25 million; 
  • Buys, sells, receives, or shares for commercial purposes the personal information of 50,000 or more consumers, households, or devices annually; or 
  • Derives 50% or more of their annual revenue from the sale of personal data. 

What Is Included? 

HB 969 would require that applicable businesses notify consumers about their data collection and selling practices before or at the point of data collection. Under this Bill, consumers would also have the right to request their data be disclosed, corrected, or edited and the right to opt-out of having their personal information disclosed or sold to a third party. 

Applicable businesses would be required to implement reasonable security protocols to protect their consumer’s personal data. Also included is a private right of action through which a consumer “whose nonencrypted and nonredacted personal information or e-mail addresses are subject to unauthorized access” may seek damages for violations of the Bill. The Department of Legal Affairs would be authorized to bring other enforcement actions, up to $2,500 per unintentional violation and $7,500 per intentional violation. 

Potential Impact 

Currently, the data privacy landscape in the United States is a patchwork of enacted and proposed laws, all with their own requirements and consumer rights, creating a confusing web for companies operating in more than one jurisdiction. While advocates of these state privacy laws argue for the protection of consumers’ data in an increasingly digitally-driven world, opponents argue that the potential risk of operating within states who have enacted comprehensive privacy laws may deter businesses from expanding their operations there. 

A federal privacy law that could rectify the many differences between individual state laws would simplify this landscape, making it easier for companies to protect their consumers’ data and operate efficiently while complying with regulations.  

Beckage is closely monitoring these, and other emerging privacy laws. In the meantime, companies that collect personal data should start thinking about privacy compliance by conducting a baseline privacy assessment and starting to develop relevant policies and procedures. Beckage attorneys, who are also technologists and certified privacy professionals, are happy to help counsel your business on compliance with the CCPA, GDPR, and other pending and enacted privacy legislation.  We work with clients of all sizes to build out data privacy programs and address compliance matters.  

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Data Privacy DayBeckage Attorneys Make 2021 Data Security & Privacy Predictions in Observance of Data Privacy Day

Beckage Attorneys Make 2021 Data Security & Privacy Predictions in Observance of Data Privacy Day

Today is Data Privacy Day – an international event held annually on January 28th with the purpose of promoting privacy and data protection best practices for consumers and businesses. At Beckage, every day is Data Privacy Day – our team of lawyers and technologists works daily with clients on data security and privacy measures, from developing policies and procedures to comply with international and domestic privacy regimes to responding to headline-making data incidents and defending clients in data security and privacy class actions.

The legal landscape surrounding data security and privacy is constantly evolving to adapt to technological advancements and global privacy trends. In observance of this holiday, we asked some of our experienced team members what they expect to see in this space in 2021.


Litigation – Myriah V. Jaworski, Esq. CIPP/US, CIPP/E

My data privacy prediction for 2021 is also related to biometrics. This year we will see the continued rise of regulation over and litigation concerning the use of biometric information.

A few years after the Illinois State Legislature passed BIPA, the Biometric Information Privacy Act, we started to see a slew of class action lawsuits filed against businesses alleged to have violated BIPA’s written release requirement. BIPA class actions have ranged from headline-making cases against major tech companies, such has Facebook, to small and medium-sized businesses across numerous industries.

While biometric lawsuits were once viewed as a risk associated only with doing business in Illinois, other states, like Washington and Texas, have followed suit by passing their own laws mimicking BIPA and others are eyeing their own biometric privacy bills. Of note, a bill nearly identical to BIPA is pending in the New York State legislature, which, if passed, could have a much larger impact on businesses given that New York is one of the largest economies in the United States.

At the federal level, we have recently seen the Federal Trade Commission (FTC) enter the biometric conversation with its consent agreement with EverAlbum, Inc. This consent order may have set a nation-wide standard for businesses’ use and collection of biometric information, regardless of whether those businesses operate in states that have enacted or pending biometric privacy laws.

In short, in 2021 the risks and penalties associated with collecting and using biometric information are steep. Any business, regardless of location, that is engaging in biometric information collection should conduct a privacy audit, look at its written policies, and ensure that it has the requisite consents in mind. As a litigator, I always say “demonstrable compliance is the strongest legal defense,” and that is certainly true in the biometric privacy space.

Watch Myriah’s video prediction here.


Incident Response – Daniel P. Greene, Esq., CIPP/US, CIPP/E

At the heart of what we do as incident response privacy practitioners is data breach prevention.  My 2021 prediction for the privacy landscape is an expansion in the use of multi-factor authentication. This is great news for incident response because, often, multi-factor authentication is an important step in helping to avoid a data incident and protect the privacy of data.

Multi-factor authentication is when a user identifies themself through biometrics, like a facial or fingerprint scan, or though entering a code on a device to confirm access to sensitive spaces, like a bank account or work network. It helps in avoiding unauthorized access and we expect to see this technology used in new spaces in 2021, such as when using an ATM or checking out at a grocery store.

We also anticipate an expansion in the use of biometrics over device authentication. There have been numerous documented incidents where device authentication has backfired. A famous example occurred in 2019 when attackers were able to gain access to Twitter CEO Jeff Dorsey’s account using a SIM card swap scheme. Because biometric identifiers are much more difficult to change or duplicate, using a facial scan or fingerprint is a much more secure method of confirming a user’s identity. And while this brings up a host of other issues about safeguarding biometric information, I think we can expect to see it used a lot more soon.

Watch Dan’s video prediction here.


Government Investigations – Michael L. McCabe, Esq., CCEP

In 2021, I expect to see increased enforcement of privacy and data security laws and regulations at both the federal and state level. Considering new leadership in Washington D.C. and the looming impact of the COVID-19 pandemic, I predict not just an uptick in enforcement, but also a more muscular approach by regulators.  More enforcement actions are expected, a further reminder for companies to work with experienced tech privacy and security legal counsel to minimize legal and technical risk.

At the federal level, look for enhanced enforcement by the Federal Trade Commission (FTC), Federal Communications Commission (FCC), and Securities and Exchange Commission (SEC). On the state level, I anticipate a similar response by state attorneys general outside of Washington.   

In 2020, we saw a major uptick in cyber-attacks, due in part to companies having to quickly adopt policies for a distributed workforce.  There were also numerous COVID-related phishing attempts. These developments have resulted in a record number of data security incidents. Therefore, I expect the focus of these enforcement actions to be not just on privacy compliance, but also on effective data security and incident response.  

Watch Mike’s video prediction here.


Privacy Compliance – Kara L. Hilburger, Esq., CIPP-US

My prediction for the privacy compliance area in 2021 is the increased focus on consumer privacy rights. With California’s comprehensive privacy law, the California Consumer Privacy Act (CCPA), now one year old, there is increase awareness and attention to data subject rights.  With a myriad of other states entertaining statutes similar to the CCPA, I anticipate a host of plaintiff related lawsuits filed under these statutes’ privacy right of action provisions. The result is that business operating in this highly global, multi-jurisdictional environment will need to continue to work towards building out robust and scalable data security and privacy infrastructures that take into account not only the GDPR and CCPA but other emerging laws. For example, updating forward-facing website disclosure policies and user agreements will be paramount here to be sure they comply with the required disclosures.

Relatedly, my second prediction as that we will continue to see an uptick in litigation filed under the Americans with Disabilities Act and frankly no end is in sight.  Businesses are continuing to educate themselves on the legal standards necessary for building and maintaining an accessible website.  We also anticipate much in the way of legislation or increase DOJ involvement in this area under the new administration.

Watch Kara’s video prediction here.


Health Law – Allison K. Prout, Esq., Cert. AWS Cloud Practitioner

With so much of our everyday lives moving online in the wake of the COVID-19 pandemic, we have seen a large uptick in data breaches caused by third-party vendors and service providers. And when it comes to the healthcare industry, I anticipate a continued increase in incidents that originate with business associates and other vendors providing services to covered entities. 

 In fact, about 40% of HIPAA breaches involve or are caused by business associates. With a new administration that’s likely to favor regulatory action, we expect to see regulatory authorities continue to enforce actions against covered entities whose business associates or service providers experience breaches. 

So what does this mean for the industry?  We expect to see covered entities taking a much closer look at who they are working with—and whether those parties have robust security and privacy protocols. For this reason, business associates may need to prepare accordingly. Whether you are a covered entity or a business associate, now is the time to dust off vendor due diligence and monitoring policies and procedures. It’s also a good idea to take a closer look at those service agreements and business associate agreements to make sure your service providers are making the right security commitments—and assuming responsibility—when there’s a breach.

Watch Allie’s video prediction here.


Global Data Privacy – Jordan L. Fischer, Esq. CIPP/US, CIPP/E, CIPM

My first prediction for the global data privacy space in 2021 is the creation and evolution of additional data privacy regulations across the globe. The so-called “GDPR Effect” has been pushing data privacy trends across the globe, and we expect to this to continue as more regions and countries adopt legislation mimicking parts of the GDPR, putting their own unique twist on data privacy, or modernizing their existing data privacy regulations to make them more compatible with the GDPR and other global privacy regimes.

My second prediction is a major emphasis on cross-border data transfers. The 2020 Schrems II decision invalidated the EU-US Privacy Shield for sending data from Europe to the United States. This decision was focused on data transfers between the United States and the European Union, but it also highlights a challenge we are continuing to see in international law – while these privacy regulations see borders, the digital realm does not.  Thus, it is increasingly hard to segment data and maintain it within a specific region. This year, I anticipate a lot of tension between regions that approach privacy and security from various perspectives that don’t always align. This presents a challenge for businesses to continue to operate efficiently while minimizing risk and dealing with multiple global privacy and security regulations.

Regardless of the specific trends we expect to see this year, one thing is certain – the global data privacy landscape will continue to change rapidly, creating a fascinating environment for data privacy and security lawyers to practice in.  I am very excited to be a part of such a dynamic team that will continue to provide services to our clients in this space.

Watch Jordan’s video prediction here.


Key Takeaways

Today, as well as every other day of the year, we hope you take some time to reflect on data privacy and security and the ways you can better protect your personal or business’ private information. The Beckage team is passionate about to educating the masses on the importance of data security, the consumer privacy rights and the impact on businesses, and the steps you can take safeguard your information. We are committed to providing updates on relevant legislation, current threats, and proactive data security steps. Be sure to follow us on LinkedIn, read our blog, and subscribe to our newsletter to stay up to date on the latest in this ever-changing space. Happy Data Privacy Day!

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2020Looking Back on 2020’s Top Privacy and Cybersecurity Trends

Looking Back on 2020’s Top Privacy and Cybersecurity Trends

As 2020 comes to a close, Beckage looks back on the ways this difficult and unprecedented year impacted the data privacy and cybersecurity landscape both domestically and across the globe.

Enhanced Privacy Challenges and Concerns Due to Covid-19

In response to the COVID-19 pandemic, businesses around the globe made a major pivot to online or virtual operations early this year. An intentional focus on data protection and a solid understanding of the regulatory landscape is a legal requirement that demands the integration of data protection up front in any network design or business practice. The increase in exposure of company assets made it necessary to implement a variety of technical safeguards. Companies still had to meet the compliance milestones of the NY SHIELD Act and California’s Consumer Protection Act (CCPA) while dealing with new privacy challenges caused by a distributed workforce and a global health pandemic. Beckage reminds organizations of the importance of revisiting their readiness through business continuity, incident response, and more expansive administrative, technical, and physical safeguards when shifting to a work-from-home model and recommends continued assessment of your company’s privacy pitfalls in this ever-shifting legal landscape.

Increased Ransomware and Cyberattacks

With rapid changes in organizational operations caused by the COVID-19 pandemic, attackers became more sophisticated in their strategies and unleashed several unrelenting, simultaneous attacks on service providers and the organizations they serve in 2020. Victims of recent cyber attacks, such as the SolarWinds campaign carried out in December, include government agencies, healthcare providers, consulting agencies, and , technology, telecom, and oil and gas companies. In many of these campaigns, attackers were able to gain access and move freely throughout an organization’s server, installing additional software, creating new accounts, and accessing sensitive data and valuable resources while remaining largely undetected. In response to the uptick in data incidents this year, the Beckage Incident Response Team recommends organizations implement several preventative steps to safeguard their organization to help minimize legal risk.

Patient Access Rights and Interoperability

Recent developments in 2020 concerning patients’ right to access health information to implement interoperability and record access requirements intend to help patients obtain access to health records and payment data to make informed decisions about their healthcare. The CMS Proposed Rule and the OCR Proposed Rule represent a complete overhaul of well-established standards and an introduction of new and highly technical requirements with healthcare compliance. The experienced Health Law Team at Beckage can help to distill these lengthy and complicated rules so organizations can understand practical implications on daily operations.

Increased International Focus on Consumer Privacy

On the heels of EU’s General Data Protection Regulation (GDPR), many countries followed suit by establishing legal frameworks for governing how organizations collect, use, and store their citizens’ personal data. One example is Brazil’s Lei Geral de Proteção de Dados (LGPD), which went into effect in August of 2020. This general data protection law, which closely mimics the GDPR, places strict requirements on organizations that process Brazilian citizen’s personal data.

At the same time, Europe continued to elevate its enforcement of the GDPR, with major decisions from various member state Data Protection Authorities, the European Court of Justice (ECJ), and the European Data Protection Board (EDBP). The most impactful for businesses across the globe was the ECJ’s decision in Schrems II, which invalidated the EU-US Privacy Shield and called into question the long-term viability of the Standard Contractual Clauses (SCCs) to transfer data from the EU to the US. In 2021, companies should closely monitor the evolving guidance on international data transfers and be prepared to mitigate risk of global data transfers.

Beckage’s Global Data Privacy Team expects continued adoption of data protection regulations across many regions, and an emphasis on creating global security and privacy compliance programs in the year ahead.

Uptick in ADA Litigation

This past year, the Beckage Accessibility Team has witnessed a drastic increase in litigation under Title III of the Americans with Disabilities Act. On average, about eight new lawsuits are filed a day by disabled individuals alleging unequal access to goods and services provided on a company’s digital platforms. While the Department of Justice (DOJ) has consistently held that the ADA applies to websites and mobile apps, they have failed to clarify the precise requirements for a business to be deemed compliant. This has prompted a wave of litigation by plaintiffs’ who claim a website or mobile app’s incompatibility with assistive technology, like screen-reading software, has denied them full access to and equal enjoyment of the goods, services, and accommodations of the website, therefore violating the ADA. Most of these lawsuits are settled quickly out of court to avoid litigating in such uncertain legal terrain.

Beckage handles the defense of website accessibility lawsuits as well as assists companies in navigate pre and post-suit settlement agreements for this unique area of the law.  Beckage also works with clients under privilege to conduct internal and remedial audits of client websites and mobile applications, evaluate platform compatibility and oversee implementation of recommended remedial or accessibility-enhancement measures.

California Consumer Protection Act (CCPA)  

Enforcement of California’s comprehensive California Consumer Privacy Act (CCPA) began on July 1, 2020 and has brought a range of plaintiff related lawsuits under its private right of action provision expanding California breach laws. For a data breach to be actionable, the information accessed must be identified as personal information, as narrowly defined by California’s data breach notification law. Recently, in November 2020, the Consumer Right To Privacy Act (CRPA) ballot initiative was passed, creating additional privacy rights and obligations pertaining to sensitive personal information that will go into effect. CPRA also expands data breach liability created by the CCPA, adds a private right of action for unauthorized access that permits access to an account if the business failed to maintain reasonable security, and imposes data protection obligations directly on service providers, contractors, and third parties. Beckage urges businesses who operate in or serve California citizens to continue to follow CCPA developments and carefully monitor related litigation in the coming months.

Emerging Technologies

The recent expansion of the Illinois Biometric Information Privacy Act (BIPA) has resulted in numerous class actions suits against organizations alleged to have collected plaintiffs’ biometric data. With the expanding use of biometric equipment, these claims often allege defendants obtained plaintiffs’ biometric data without complying with the BIPA’s notification and consent requirements. Upcoming class suits may address the issue of BIPA having an extraterritorial effect when bringing claims against out of state vendors.

Similarly, computers that manipulate the media, known as deep fakes, advance the dangers of influenced perceptions. The advancements of deep fakes are giving rise to laws regarding defamation, trade libel, false light, violation of right of publicity, or intentional infliction of emotional distress. Sophisticated tech lawyers can assist in determining rights and technological solutions to mitigate harm. As former tech business owners, Beckage lawyers want to drive innovation with use of these new and emerging technologies while understanding standards and laws that may impact such development. Beckage recommends that companies proactively mitigate the risks associated with collecting biometric information and deep fakes to prevent legal repercussions and defamation. 

Key Takeaways

2020 proved to be an unpredictable year in more ways than one. The COVID-19 pandemic forced companies to rapidly adapt to new privacy and data security challenges caused by a distributed workforce, emerging technologies, and an increased focus on ecommerce with in-person shopping and events. As we move towards 2021 with no definitive end to the pandemic in sight, it is crucial for companies to prioritize data privacy and cybersecurity initiatives by consulting qualified legal tech experts who can help navigate the uncertainty next year will bring. Beckage attorneys can assist in creating, implementing, and evaluating robust data security and privacy infrastructures that will help put your business in a position to tackle all the challenges 2021 has in store.

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DFSLessons Learned from DFS’s First Enforcement Action Under the DFS Cybersecurity Regulation

Lessons Learned from DFS’s First Enforcement Action Under the DFS Cybersecurity Regulation

The DFS Cybersecurity Regulation 22 NYCRR 500 (“Regulation”) requires businesses operating under NY banking, insurance, and finance laws to implement and maintain certain cybersecurity practices, including risk assessments, documentation of security policies, management of third-party providers, and set strict requirements for data breach reporting.  Even though the Regulations were issued in March 2017, they did not become fully effective until March of 2019, following a two-year phased implementation process.

On Wednesday, July 22, the Department of Financial Services (“DFS”) filed its first enforcement action against a leading title insurance provider alleging multiple violations of the Regulation.  This enforcement action provides important guidance to those covered entities subject to the Regulation and signals that the DFS is now ready to actively begin enforcing it.  This, of course, comes at an interesting time given the heightened risks and challenges organizations face because of the COVID-19 pandemic.

Enforcement Action Summary

The enforcement action at issue alleges that a vulnerability resulted in the exposure of millions of files that included consumers’ bank account numbers, mortgage and tax records, social security numbers, wire transaction receipts, and driver’s license images.  Of note, the DFS alleges that the respondent:

1. Failed to follow its own policies to conduct a security review and risk assessment of the vulnerability and the exposed information.

2. Misclassified the vulnerability within the system as “low” severity and failed to investigate the vulnerability within its own defined time period.

3. Failed to conduct a reasonable investigation into the scope and cause of the exposure after the data exposure was discovered.

4. Failed to follow the recommendations of its internal cybersecurity team to conduct a further investigation into this vulnerability.

5. Did not implement centralized and coordinated training to protect against the unauthorized exposure of sensitive information.

The DFS alleges that these errors not only led to a data exposure that lasted a few years but also violated six provisions of the DFS’s Cybersecurity Regulation including:

1. Section 500.02 requiring a cybersecurity program informed by risk assessment

2. Section 500.03 requiring a written policy approved by a senior officer of the board of directors

3. Section 500.07 requiring access controls

4. Section 500.09 requiring periodic risk assessments

5. Section 500.14(b) requiring regular training

6. Section 50015 requiring encryption in transit and at rest

The Regulation is pursuant to Section 408 of the Financial Services Law, which carries penalties of up to $1,000 per violation in respect to a financial product or service, including title insurance. The DFS alleges that each instance of Nonpublic Information within the charges constitutes a separate violation carrying up to $1,000 in penalties per violation.  This action is scheduled for a hearing before NYDFS beginning on October 26, 2020.

The full DFS press release on its enforcement action is available here.

Lessons Learned

Businesses should follow their own policies, focus on employee training, and employ people who are well adverse in data security and privacy.

-Businesses should not underestimate the level of risk associated with vulnerabilities.

-Business must follow their own cybersecurity policies and related internal policies and procedures.  If representations are made throughout policies, it is critical that they are adhered to.  For example, if the policy commits to performing a risk assessment, it is imperative that the business carry out its commitment and perform the risk assessment.

-Vulnerabilities must be regularly reviewed and identified.  They must be taken seriously, and any security lapses must be addressed.

At Beckage, our lawyers are also technologists and are highly knowledgeable in cybersecurity and data privacy and regulatory compliance. We have worked with numerous businesses on DFS inquiries and regulatory compliance efforts including policy development and training.  Our team can help your company mitigate risks, while assessing the effectiveness of your cybersecurity program. Beckage will help you better understand the Regulation’s requirements and legal implications while also helping reduce risk and manage privacy matters.

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