CCPA: Hotel Loyalty Programs, Data Retention and the Brave New World of Privacy By Robert E. Braun This article first appeared in the Hotel Business Review and is reprinted with permission from www.HotelExecutive.com. The California Consumer Privacy Act (the “CCPA” or the “Act”) is a piece of consumer privacy legislation…
As most (but not all) business know, the California Consumer Privacy Act of 2018 (the “Act” or “CCPA”) goes into effect January 1, 2020. It is estimated that more than 500,000 companies are subject to the CCPA, many of them smaller and mid-size businesses that may not have pre-existing robust…
Complying with the California Consumer Privacy Act in 5 (more or less) Not So Easy Steps Part 3 of a Series The Privacy Policy This is the third in a series of articles on complying with the California Consumer Privacy Act (CCPA). The CCPA is estimated to directly impact more…
Public Service Announcement: Social media use increases your cybersecurity exposure. Share appropriately. If that were all it took. In my earlier post, I described how casual use of social media (that is, failure to take into account its impact on privacy and security) can put your company’s information security profile…
Looking back with the perspective of two years, the Equifax data breach still has many lessons to teach us. Unfortunately, some of the most important lessons are masked by the extremes of the errors that characterized the original breach, which include insider trading by top executives after the breach was…
Written prior to Marriott International’s announcement on November 30, 2018 that a data breach exposed the private data of up to 500 million guests, Robert Braun, co-chair of JMBM’s Cybersecurity & Privacy Group, wrote the article Guest Privacy – It’s Your Business, published by HotelExecutive.com on December 2, 2018. In…
Today’s revelation by Marriott International that a data breach exposed the names and personal details of over 500 million guests sent a shudder throughout the hospitality industry worldwide. Hoteliers know they are an appealing target for hackers as their databases contain identifying and financial information for very large numbers of…
The SEC warns public companies that lax cybersecurity practices could violate rules governing internal accounting controls, and offer nine scams as cautionary tales. The SEC has become increasingly active when it comes to cybersecurity. Last month, it issued an investigative report about Business Email Compromises (BCEs) involving nine public companies…
Cybersecurity is a method to protect your data and systems. Cyber resiliency is a way of doing business in the face of the inevitable. When Hurricane Michael struck the Florida Panhandle earlier this month, it wiped away wide swaths of Mexico Beach, a coastal town on the Gulf of Mexico.…
On June 28, 2018, Governor Brown signed the California Consumer Privacy Act of 2018, which goes into effect on January 1, 2020. But – because of certain look-back features in the new law – significant compliance will be required by January 1, 2019. The Act is enforceable by the California…