While the GLBA Privacy Rule focuses primarily on notice and disclosure, the GLBA Safeguards Rule centers around how NPI is protected. It mandates that financial institutions develop an information security plan in writing that describes all of the procedures and processes seeking to protect client NPI.
The EU-US Adequacy Decision has been recently adopted, replacing the Privacy Shield to guide companies transferring data between the two countries through self-certification under the EU-US Data Privacy Framework.
Are you looking to hire one person to combine the Chief Compliance Officer and General Counsel roles? Or maybe you’ve heard that combining them is not a good idea and need to know why. Our compliance experts help fintech founders and executives understand the differences between Legal and Compliance by answering a few typical questions.
Financial institutions often share their customers’ and consumers' financial information with business partners and affiliates. In order to protect citizens’ privacy and decrease the likelihood of identity theft, in 1999 the United States Congress passed the Gramm-Leach-Bliley Act (GLBA), also known as the Financial Services Modernization Act.
On January 6, 2021, it was announced that Ascension Data and Analytics, LLC ("Ascension") settled a lawsuit with the Federal Trade Clinician ("FTC") which claimed that they breached the Gramm-Leach-Bliley Act ("GLBA") Safeguard Rules by failing to properly assure that the security provisions of their third-party service provider to ensure if properly protected consumers identifying financial information. This case serves as a warning to all companies using third party vendors.
