Preparing for the Expected and the Unexpected: The New York Department of Financial Services' Cybersecurity Regulation
While the sufficiency of cybersecurity programs was previously subject to "reasonableness" standards, an "acceptable" cybersecurity program has become more objective as regulators, such as NYDFS, continue to implement, amend and mature applicable laws.
March 01, 2024 at 10:00 AM
9 minute read
When the first public data breach occurred in 2005, there was little to no legal oversight in place. In response to data breaches, the threat actors typically garnered the exclusive responsibility. As the law has evolved and data security incidents have become more common, public and regulatory sentiment has shifted from blaming the threat actor toward holding the victim company accountable based on its purportedly deficient cybersecurity program.
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