Data breaches transforming the GC's role in the company
If nothing else, the disasters at Target and Neiman Marcus offer portentous reminders to boards and C-suites that the OGC must play a ground-floor role in forging a data breach response plan.
February 23, 2014 at 07:00 PM
7 minute read
Front-page breaches have transformed the corporate landscape and, with it, the role of general counsel. First, the table stakes — the day-to-day lawyering that defines the work of the office of the general counsel (OGC) under any circumstances — are higher. Not merely job description details, these changes are significant indices of the sheer magnitude of the crisis at hand.
For example: The regulatory burden is broader and deeper, a complex web potentially entangling HIPAA, Gramm-Leach-Bliley and state regulations. It's a new labyrinth demanding higher-level in-house practice.
The OGC must be a fixture of enterprise-wide training programs. It is now the GC's responsibility to ensure that employees at every level understand applicable policies.
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