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A date for the diary 26.10.2020. First American Insurance looks to be the first company to be charged under NYDFS NYCRR 500. The charges allege that between October 2014 and May 2019 the company allowed access to over 885 Mn client records. Failing to address cyber security requirements.
The charges reference a range of violations detailed in the enclosed Statement of Charges. Including failing
1. To implement a risk based cyber security
programme.
2. To maintain written policies and procedures and
data governance and classification based upon risk assessments, approved by the
Board of Directors.
3. To appropriately manage access controls to NPI
systems.
4. To implement appropriate compensating controls,
signed-off by the CISO.
5. To encrypt Non-Public Information and other
sensitive information.
6. To provide appropriate security education and
awareness training.
This will be one to watch, being the first over the
line with no precedents set.
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