WARNING: Privacy and Data Breach

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Presentation transcript:

WARNING: Privacy and Data Breach Joe Crouse Legislative Counsel Consumer Bankers Association

WARNING: Privacy and Data Breach Introduction Evolution of Privacy Regulation Status Quo Compliance

WARNING: Privacy and Data Breach The Evolution of Privacy Regulation--Overview Social Security Number Restrictions Gramm / Leach / Bliley FACT Act Data Breach

WARNING: Privacy and Data Breach Status Quo Federal Status Quo FTC Guidance FACT Act Disposal Rule Enforcement State Laws ("Emerging Status Quo") Social Security Number Restrictions Data Breach Data Breach Reaction Plan

WARNING: Privacy and Data Breach Status Quo, cont. Preemption: The Price "Trigger Terms": Unresolved Questions

WARNING: Privacy and Data Breach Compliance Plan Electronic and Paper-Based Media Handling Logging and Data Collection Service-Provider Oversight Intrusion Detection and Response

WARNING: Privacy and Data Breach Compliance Plan, cont. Business Continuity Considerations Insurance Security Testing Monitoring and Updating

WARNING: Privacy and Data Breach Closing and Questions