By Kevin Boyle & Alex Stout Hardly a day passes now without some new report of a security vulnerability with inevitable breaches that follow, but Monday’s news about the two-year old vulnerability in OpenSSL is (or should be) catching everyone’s attention. The problem is a coding error in a widely used cryptographic software library for … Continue Reading
By, Jeremy M. Alexander, Natalie E. Brown & Susan A. Ebersole The day all covered entities and business associates have been working toward is here—September 23, 2013, the deadline to comply with the changes in the HIPAA omnibus final rule, published on January 25, 2013. Here is a review of the top three compliance categories … Continue Reading
By Justin B. Cornish, Brian A. Meenagh, Alice Marsden and Omar M. Elsayed Protecting Personal Data Whilst it is not widely recognized that countries in the Middle East have specific established laws applicable to data protection, privacy and data protection are regulated by other laws in the region. In Qatar, Saudi Arabia and the United … Continue Reading
By Elizabeth Richards and Kevin Boyle On June 14, 2013, the Food and Drug Administration (“FDA”) issued a draft guidance entitled, “Content of Premarket Submissions for Management of Cybersecurity in Medical Devices.” (“Guidance”). The Guidance was issued in response to growing concerns about IT vulnerabilities due to the increased use of wireless, Internet and network-connected … Continue Reading
By Omar Elsayed Although some surveys of privacy law suggest otherwise, privacy requirements do in fact exist in the Kingdom of Saudi Arabia (KSA)and are very relevant to companies operating there or seeking to provide services to customers in KSA. Background The paramount body of law in KSA is the Sharīʿah. The Sharīʿah is comprised … Continue Reading
By Susan Ambler Ebersole HHS today published the long-awaited HIPAA/HITECH omnibus final rule. A pre-publication version of the Rule was released on January 17. The Rule is effective March 26, 2013, but covered entities and business associates have until September 23, 2013 to comply. While Latham & Watkins is still engaged in a comprehensive review … Continue Reading
By Jennifer Archie and Suan Ambler-Ebersole Second Highest HIPAA Settlement Amount to Date and First Paid by a State The U.S. Department of Health and Human Services (HHS) Office for Civil Rights (OCR) announced Tuesday that it had reached a settlement with Alaska’s state Medicaid agency, the Department of Health and Social Services (DHSS) for $1,700,000 … Continue Reading
The American Institute of Certified Public Accountants (“AICPA”) Statement of Auditing Standard No. 70, or SAS 70 as it is more commonly known, has been with us since April 1992. On 15 June 2011, it will effectively be replaced by two new standards: (i) a reporting standard for service organisations, the “Statement on Standards for … Continue Reading
Google has consented to the entry of a proposed Agreement Containing Consent Order with the US Federal Trade Commission, subjecting the company to sweeping government oversight of its privacy disclosure and product development and release practices, nominally arising out of the roll-out of its Buzz product in February 2010. The auditing and reporting requirements are … Continue Reading
The Interim Final Rule for Breach Notification for Unsecured Protected Health Information, issued pursuant to the Health Information Technology for Economic and Clinical Health (HITECH) Act, was published in the Federal Register on August 24, 2009, and became effective on September 23, 2009. During the 60-day public comment period on the Interim Final Rule, HHS received approximately 120 comments. HHS reviewed … Continue Reading