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Accounting for Cyber Security Part Three – Cloud Service Providers and ISO 27001

In Parts One and Two of this article we discussed the new Guidance issued by the Securities and Exchange Commission (SEC) Division of Corporation Finance that provides guidance to companies with regard to whether and how a company should disclose the impact of the risk and cost of cybersecurity incidents…

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Binding Corporate Rules System under Review

Hot on the heels of the UK Information Commissioner’s approval of First Data’s binding corporate rules (BCRs), Viviane Reding, the Vice President of the European Commission and EU Justice Commissioner has signalled reform of the BCR scheme aimed at making BCRs even more effective. BCRs are a way of ensuring…

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First Data Corporation binding corporate rules approved

14 November 2011 saw First Data Corporation become the 11th entity to have binding corporate rules (BCRs) approved by the UK’s Information Commissioner’s Office (ICO). First Data Corporation is a global electronic commerce and payment processing company. As a payment processor, secure handling of data is at the heart of…

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e-Commerce Risks during Cyber Monday and the Holiday Shopping Season

The holiday shopping season in the U.S. started in earnest on Black Friday (or even Thursday for some stores) and online shopping celebrates today with “Cyber Monday.” Contrary to popular belief that Black Friday is the day that retailers go from being in the “red” to being in the “black”…

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Doing Business in Europe? Social Media Prosecution in Germany Flags Data Consent Problem

Do you transfer personal data from Europe to the US? Do you use cookies on a website aimed at European customers? Do you send marketing emails to Europe? Do you otherwise “process” data in Europe? Do you really have consent to process personal data? If any of these questions strike…

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Accounting for Cybersecurity – (Part 2 of 4)

In Part One of this article, we looked at the Securities and Exchange Commission (SEC) Division of Corporation Finance’s recent release – CF Disclosure Guidance: Topic No. 2 – Cybersecurity (the “Guidance”), which is intended to provide guidance to companies on whether and how to disclose the impact of the…

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Accounting for Cybersecurity – Part One

On October 13 the Securities and Exchange Commission (SEC) Division of Corporation Finance released CF Disclosure Guidance: Topic No. 2 – Cybersecurity (the “Guidance”), which is intended to provide guidance to companies on whether and how to disclose the impact of the risk and cost of cybersecurity incidents (both malicious…

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Beyond Cheap Labor Outsourcing: IT Operations Automation

For the past decade or so, IT organizations looking to lower delivery costs have outsourced day-to-day IT operations activities to IT suppliers who in turn send the work to low cost locations (primarily India). Typically, this is done by executing a knowledge transfer process whereby the IT suppliers capture the…

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