Last month, the Financial Services Information Sharing and Analysis Center[1] (“FS-ISAC”) warned financial services companies, and particularly smaller firms, of a substantial increase in attempted cyberattacks since the start of the COVID-19 pandemic.  In particular, cyber-attacks targeted at bank employees rose in the first quarter of 2020.  As of early April, FS-ISAC had also identified over 1,500 fraudulent or phishing websites designed to look like pandemic-related lending or financial support programs to deceive visitors into disclosing sensitive personal information.
Continue Reading FS-ISAC Warns that Cyberattacks Against Financial Services Firms Increased Substantially in Response to COVID-19 Mitigation Efforts

As many organisations adjust their business operations as a result of the COVID-19 pandemic, network and data security are in the spotlight.  The significant increase in remote working, brings unique challenges and organisations must remain mindful of their legal obligations to keep personal data secure.  In particular, the EU General Data Protection Regulation (“GDPR”) imposes a general obligation upon data controllers and processors to ensure the security of data processing against accidental or unlawful loss, damage, destruction, alteration or disclosure.

Controllers and processors must have in place appropriate technical and organisational measures to ensure a level of security for personal data that is commensurate to the risk associated with data processing.  This is not a static analysis, but something to be kept under review as circumstances change.  The mass shift to remote working has inevitably changed the risk profile of certain data processing activities.  Set out below is a summary of important considerations from a data security standpoint, taking into account the GDPR’s requirements as well as guidance from data protection supervisory authorities in the UK, France, Belgium, Germany and Italy.
Continue Reading COVID-19 Remote Working – GDPR Data Security Checklist

As firms respond to the ongoing coronavirus pandemic by increasingly transitioning to remote and telework arrangements, the Financial Industry Regulatory Authority (“FINRA”) issued an alert on measures that firms and associated persons can take to address resulting cybersecurity vulnerabilities:

  • Measures for Firms. Firms should take steps to ensure network security.  This may include providing

Efforts to contain COVID-19 have resulted in many employees working remotely for potentially an extended period of time.  While such precautions are in place, it is important to stay vigilant of cybersecurity risks.  There are already reports of COVID-19 related phishing scams and a recent hack of the U.S. Health and Human Services Department amid its pandemic response.  Remote working can exacerbate these risks.  Below is a checklist of key issues to keep in mind on this subject:
Continue Reading Managing Cyber Risk During COVID-19 Response