March 6, 2024

New York Strengthens Data Retention & Disposal Requirements

This article was originally published in Corporate Compliance Insights, February 2024


Companies may find existing systems need augmenting to meet new rules

Recent amendments to the New York Department of Financial Services 23 NYCRR Part 500, which more than a half-decade ago transformed cybersecurity compliance for thousands of insurance, financial services and healthcare organizations, threaten to shake things up again by adding new requirements. Joseph Shepley of Alvarez & Marsal offers guidance to CISOs at covered organizations.

The New York Department of Financial Services’ 23 NYCRR Part 500 has been a part of the compliance landscape for insurance, financial services and healthcare organizations since 2017. Part 500 has transformed the cybersecurity posture of these covered entities, benefiting consumers, employees and other data subjects whose personal data organizations process.

While all the recent amendments to Part 500 have been the subject of considerable discussion, the changes to Section 500.13 will likely have the biggest weight, governing how covered entities manage (and dispose) of their non-public information (NPI) so they can remain Part 500 compliant.

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