As reported in the Hunton Nickel Report:

Recent press reports indicate that a cyber attack disabled the third-party platform used by oil and gas pipeline company Energy Transfer Partners to exchange documents with other customers. Effects from the attack were largely confined because no other systems were impacted, including, most notably, industrial controls for critical infrastructure. However, the attack comes on the heels of an FBI and Department of Homeland Security (“DHS”) alert warning of Russian attempts to use tactics including spearphishing, watering hole attacks, and credential gathering to target industrial control systems throughout critical infrastructure, as well as an indictment against Iranian nationals who used similar tactics to attack private, education, and government institutions, including the Federal Energy Regulatory Commission (“FERC”). These incidents raise questions about cybersecurity across the U.S. pipeline network. Continue Reading Attacks Targeting Oil and Gas Sector Renew Questions About Cybersecurity

On March 15, 2018, the Trump Administration took the unprecedented step of publicly blaming the Russian government for carrying out cyber attacks on American energy infrastructure. According to a joint Technical Alert issued by the Department of Homeland Security and the FBI, beginning at least as early as March 2016, Russian government cyber actors carried out a “multi-stage intrusion campaign” that sought to penetrate U.S. government entities and a wide range of U.S. critical infrastructure sectors, including “organizations in the energy, nuclear, commercial facilities, water, aviation and critical manufacturing sectors.” Continue Reading U.S. Blames Russia for Cyber Attacks on Energy Infrastructure

What were the hottest privacy and cybersecurity topics for 2017? Our posts on the EU General Data Protection Regulation (“GDPR”), EU-U.S. Privacy Shield, and the U.S. executive order on cybersecurity led the way in 2017. Read our top 10 posts of the year. Continue Reading Privacy and Information Security Law Blog’s Top 10 Posts of 2017

As reported in BNA Privacy Law Watch, on August 22, 2017, the Russian privacy regulator, Roskomnadzor, announced that it had issued an order (the “Order”), effective immediately, revising notice protocols for companies that process personal data in Russia. Roskomnadzor stated that an earlier version of certain requirements for companies to notify the regulator of personal data processing was invalidated by the Russian Telecom Ministry in July. Continue Reading New Data Processing Notice Requirements Take Effect in Russia

As reported in BNA Privacy & Security Law Report, on August 9, 2017, the Russian privacy regulator, Roskomnadzor, expanded its list of nations that provide sufficient privacy protections to allow transfers of personal data from Russia. Russian law allows data transfers to countries that are signatories to the Council of Europe’s Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data (the “Convention”), and to certain other non-signatory countries deemed by Roskomnadzor to have adequate privacy protections based on relevant data protection laws, privacy regulators and penalties for privacy law violations. Continue Reading Russian Privacy Regulator Adds Countries to List of Nations with Sufficient Privacy Protections

As reported in BNA Privacy Law Watch, on July 1, 2017, a new law took effect in Russia allowing for administrative enforcement actions and higher fines for violations of Russia’s data protection law. The law, which was enacted in February 2017, imposes higher fines on businesses and corporate executives accused of data protection violations, such as unlawful processing of personal data, processing personal data without consent, and failure of data controllers to meet data protection requirements. Whereas previously fines were limited to 300 to 10,000 rubles ($5 to $169 USD), under the new law, available fines for data protection violations range from 15,000 to 75,000 rubles ($254 to $1,269 USD) for businesses and 3,000 to 20,000 rubles ($51 to $338 USD) for corporate executives. Continue Reading New Data Protection Enforcement Provisions Take Effect in Russia

On January 13, 2016, the Russian Data Protection Authority (Roscommandzor) released its plan for audits this year to assess compliance with Russia’s data localization law, which became effective on September 1, 2015. The localization law requires companies to store the personal data of Russians in databases located in Russia. The audit plan indicates that the Roscommandzor will audit large, multinational companies doing business in numerous jurisdictions and processing the personal data of Russian citizens.

Data localization has been a matter of widespread concern in recent weeks. In an article published in the International Association of Privacy Professionals’ Privacy Perspectives, Hunton & Williams partner Manuel Maisog explains why lessons from China’s past show that its future should have little room for data localization. Maisog states that “[w]hile data localization has most recently and dramatically come to prominence in the form of Russian data localization legislation,” it currently “is a global issue.” He continues to say that “the Internet has linked the world’s information platforms so seamlessly that the effects of a successful data localization effort in any one major country or economy would make itself felt globally and immediately.”

Continue Reading Data Localization in a Chinese Context

On December 31, 2014, Russian President Vladimir Putin signed legislation to move the deadline for compliance to September 1, 2015, for Federal Law No. 242-FZ (the “Localization Law”), which requires companies to store the personal data of Russian citizens in databases located in Russia. The bill that became the Localization Law was adopted by the lower chamber of Russian Parliament in July 2014 with a compliance deadline of September 1, 2016. The compliance deadline was then moved to January 1, 2015, before being changed to September 1, 2015 in the legislation signed by President Putin.

Continue Reading Deadline for Compliance with Russian Localization Law Set for September 1, 2015