Tag Archives: disclosure obligation

Will Facebook’s IPO Cybersecurity Disclosures Set the Tone Under SEC’s New Guidance?

Photo of Craig A. HoffmanBy Craig A. Hoffman on Posted in Cybersecurity, Data Breach Notification Laws, Information Security
Facebook filed its long-awaited Form S-1 with the SEC on February 1.  Given the nature of its business, concerns regarding data privacy were peppered throughout the filing.  While other business risk factors may be paramount (e.g., reliance on Zynga, slowing growth, etc.), data privacy has been and will continue to be an important issue for … Continue Reading

SEC Provides Guidance on Cybersecurity Disclosure Obligations

Photo of Craig A. HoffmanBy Craig A. Hoffman on Posted in Cybersecurity, Data Breaches, Information Security
The SEC released a guidance document on October 13, 2011, which set forth the views of the Division of Corporation Finance regarding disclosure obligations relating to cybersecurity risks and incidents.  Even though there is no disclosure requirement specific to cybersecurity risks and incidents, information about such incidents and their effects may need to be disclosed … Continue Reading
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