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

As public pressure increases on legislators to better protect the personal information that organizations collect, interest has grown in using a property framework, rather than the current privacy model. On October 1, U.S. presidential candidate Andrew Yang became the latest policymaker to advocate for a data security framework that treats
Continue Reading Should Protection of Personal Data Be Regulated Using A Property Model, Rather Than a Privacy Model? Probably Not.

Two-factor authentication is one of the most common measures that companies use to reduce cyber risk, but it is not very effective if companies don’t also have a good lost-phone protocol.

Various regulations and industry rules require two-factor authentication (also referred to as multi-factor authentication or MFA) including the NYDFS
Continue Reading The Weakness in Two-Factor Authentication—Your Lost-Phone Policy

Some of the most significant recent cyber breaches originated at vendors.  We have previously discussed the importance of effective oversight of third parties because vendor breaches can lead to regulatory actions for companies.  Indeed, recent regulatory guidance provides that vendor diligence is an essential part of any cybersecurity program.  This
Continue Reading Cybersecurity Vendor Due Diligence—Some Practical Tips from the Front Lines