Broker-dealer firms are well advised to review and update their privacy policies, in light of the Securities and Exchange Commission’s (“SEC”) recent enforcement and investigation activities arising from Regulation S-P. According to trade press, recently the SEC informed one independent broker-dealer firm, Next Financial Group, Inc. of Houston, Texas, that it may file a “privacy” … Continue Reading
On March 21, 2007, eight federal regulatory agencies (“Joint Agencies”) with jurisdiction over Gramm-Leach-Bliley Act (“GLBA”) regulated “financial institutions” issued an interagency proposal for a new model privacy form. The proposal is the result of a lengthy process the Joint Agencies began in 2001 to improve the format of GLBA privacy notices to make them more … Continue Reading
The Office of the Inspector General (“OIG”) recently issued a 199-page report detailing the FBI’s use, and abuse, of national security letters (“NSLs”) to obtain information in the name of national security. The report cites repeated failures by the FBI to follow even the abbreviated procedures available under the current NSL regime for seeking customer and … Continue Reading
Welcome to the Proskauer Privacy Law Blog. Proskauer’s Privacy and Data Security Practice Group is tremendously pleased to bring you what we hope will become a trusted source for summary and analysis of breaking legal developments in the evolving field of privacy and data security law. This blog is designed in part to complement our … Continue Reading
On January 10, 2007 the Article 29 Data Protection Working Party announced the adoption of a new Model Application for the submission of a company’s Binding Corporate Rules to any European Union Data Protection Authority (DPA). The EU’s approval of the Model Application is long-awaited and a welcome addition to help make Binding Corporate Rules a … Continue Reading
Last month, a group of eight Republican lawmakers introduced H.R. 837, the Internet Stopping Adults Facilitating the Exploitation of Today's Youth (SAFETY) Act 2007. The bill would give the Attorney General very broad authority to enact rules requiring Internet Service Providers ("ISPs") to retain records so law enforcement could access their customers' online activities.
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