Yesterday, March 27, the U.S. Cybersecurity and Infrastructure Security Agency published the Notice of Proposed Rulemaking under the Cyber Incident Reporting for Critical Infrastructure Act of 2022. It is important to note that these are draft rules and do not, on their own, require organizations to report any incidents until after a Final Rule is published. CISA expects to publish the Final Rule in late 2025 with an effective date at least 60 days after publication. This is likely to push the effective date into 2026.
On Monday, the U.S. Department of Health and Human Services Office for Civil Rights issued updated guidance on the use of online tracking technologies by covered entities and business associates (here, referred to as “regulated entities”) under the Health Insurance Portability and Accountability Act Privacy Rule. The intent of the guidance is to provide regulated entities with considerations when using tracking technologies on their websites and mobile applications.
The Constangy Cyber Advisor posts regular updates on legislative developments, data privacy, and information security trends. Our blog posts are informed through the Constangy Cyber Team's experience managing thousands of data breaches, providing robust compliance advisory services, and consultation on complex data privacy and security litigation.
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