Ms. LiCalzi is an associate in Davis Polk's Litigation Department. [Full Bio]

On November 1, Canada provided the U.S. with another model for a national breach law:  the Personal Information Protection and Electronic Documents Act (“PIPEDA”).  Under that law, companies are required to notify Canada’s Privacy Commissioner and affected individuals as soon as feasible if they experience “any breach of security safeguards
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A recent SEC Order should be a reminder to registered entities, including small- and medium-sized firms, that the SEC is monitoring the reasonableness of their cybersecurity policies and procedures, and that it may take action in the event of a breach, even in the absence of economic harm.

The SEC’s
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In the lead-up to the EU’s General Data Protection Regulation (“GDPR”) becoming effective on May 25, little attention was paid in the U.S. to the private right of action that the GDPR creates. But so far, private actors have filed approximately 24 cross-border GDPR complaints with EU regulators.

At least
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