Michelle Reed Interviewed by MCC on New York’s New Cybersecurity Regulations
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Akin Gump litigation partner Michelle Reed has been featured in the Metropolitan Corporate Counsel article “Getting in Line with the New Regulations,” in which she examines new cybersecurity regulations from the New York Department of Financial Services and discusses what they mean for covered entities and the in-house counsel who advise them.
Reed discussed the novelty of the new regulations, noting that they are “the first of their kinds nationwide,” and that they apply to state chartered banks, licensed lenders, private bankers, mortgage companies, insurance companies and other service providers. Adherence, she said, was required as of August 28.
Reed proceeded to discuss additional requirements of the regulations, certain exemptions, and how the regulations will be enforced. She also outlined the importance of training to execute an incident response plan, and what the in-house lawyer’s role is in cybersecurity for covered entities, including the requirements for breach notifications, noting that you have to have “someone who is familiar with the rules and the decision-making process on when to notify, how you determined it, how you determined what data was accessed, how you determined if it was a successful breach or an unsuccessful breach.”
Finally, Reed addressed what covered entities need to know with regard to data retention, encryption and multifactor authentication within the context of the new regulations.
To read the full article, please click here.