Life with GDPR

Tom Fox and Jonathan Armstrong, renowned experts in cyber security, co-host the award-winning Life with GDPR. This episode discusses the complex topic of liability for the Chief Compliance Officer (CCO) and Chief Information Security Officer (CISO).

Tom and Jonathan begin by examining notable cases like Joe Sullivan, the former CISO at Uber, who faced prosecution for mishandling a ransomware threat. They also cover other significant cases like Carlos Abarca from TSB Bank and Tim Brown from SolarWinds, highlighting the increasing trend towards personal liability among high-ranking compliance and security officers. Jonathan points out that prosecutors and legislators focus more on individual accountability, driven by the belief that this approach will encourage others to adhere to standards more rigorously. They explore the implications of misleading LinkedIn profiles and the importance of thorough due diligence when taking on new roles. The episode provides practical advice for C-suite executives to protect themselves, including negotiating indemnity clauses and ensuring accurate job descriptions.

Key takeaways:

• Chief Compliance Officer Liability Overview
• Case Studies: Joe Sullivan and Uber, Carlos Barker and TSB Bank and Tim Brown and SolarWinds
• Legislation and Trends in Personal Liability
• SEC Formula for CCO Liability

Resources:

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Life with GDPR was recently honored as a Top Data Security Podcast 

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Tom Fox and Jonathan Armstrong, renowned expert in cyber security, co-host the award-winning Life with GDPR. In this episode, they discuss a pressing deadline for compliance officers: the February 2nd enforcement of the EU AI Act’s prohibitions on unacceptable AI risk.

Tom and Jonathan look at the phased implementation of this complex legislation, detailing the obligations of businesses using AI in their EU operations. Jonathan emphasizes the importance of identifying ‘shadow AI’ within organizations, from HR recruitment tools to consumer applications, and the substantial penalties for non-compliance, which can reach up to $35 million or 7% of global annual revenue. They also cover a practical five-step plan to help companies move towards compliance, involving board awareness, an AI inventory, assessment of AI tools, contract reviews, and transparency measures. Tune in to understand the nuances of this legislation and how to prepare your organization before the rapidly approaching deadline.

Key takeaways:

• Understanding the EU AI Act
• Prohibited AI Applications
• Corporate and Personal Liability
• Steps to Compliance

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Tom Fox and Jonathan Armstrong, renowned expert in cyber security, co-host the award-winning Life with GDPR. This episode delves into the UK’s Failure to Prevent Fraud guidance.

The podcast spans the initial implications and conflicts these new provisions present, especially in the context of GDPR and compliance with bribery investigations. Jonathan explains the concept of ‘failure to prevent fraud,’ drawing parallels with the 2010 UK Bribery Act, and outlines six key principles organizations must adhere to to demonstrate compliance. Additionally, the episode delves into specific steps compliance professionals should take before the new provisions come into force by July 2025, including gap analysis, policy updating, training, and more.

Key takeaways:

• Failure to Prevent Bribery and Fraud
• New Legislation and Its Implications
• Reasonable Procedures Under the Failure to Prevent Fraud Act
• Comparing Fraud and Bribery Compliance
• Steps for Compliance Professionals

Resources:

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Tom Fox and Jonathan Armstrong, renowned expert in cyber security, co-host the award-winning Life with GDPR.

In this episode, we delve into the complex provisions of the new EU AI Act, exploring its global effects and extraterritorial implications similar to the GDPR.

Tom, Jonathan and a few friends discuss the multifaceted regulatory framework, which combines elements from EU antitrust law, GDPR, and EU medical device rules, and highlight the need for transparency and compliance for AI developers and corporations using AI. We also address enforcement timelines, the importance of an AI inventory, and practical steps for compliance officers to ensure adherence to the new regulations.

Key Takeaways:

• Overview of the EU AI Act
• Enforcement and Compliance
• Corporate Responsibilities and Compliance Strategies
• Enforcement Mechanisms and Penalties
• Practical Steps for Organizations
• Challenges and Governance

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Tom Fox and Jonathan Armstrong, a renowned expert in cybersecurity, co-host the award-winning “Life with GDPR.” Jonathan has returned from his hiatus, and in this episode, we examine the UK election results and their potential impact on compliance.

The recent UK election has significant implications for compliance, particularly concerning the dynamics between the UK’s Serious Fraud Office (SFO) and the new government. Jonathan Armstrong, an expert on bribery enforcement, anticipates that the new administration under Keir Starmer will focus on high-profile issues like the PPE scandal while maintaining robust enforcement actions, including dawn raids.

Armstrong and Fox bring deep insights into the potential compliance landscape, shaped by their extensive backgrounds: Armstrong’s expertise in corruption investigations and Fox’s experience with the criminal justice system.

Fox highlights the impact of the new Prime Minister’s legal background in bolstering enforcement efforts and contemplates the future governance of AI under this administration. Both experts foresee a political shift, with Armstrong expecting the Conservative Party to lean rightward yet occupy the political center, and Fox emphasizing the continuity and experience the new government brings to compliance and enforcement issues.

Key Takeaways:

• Heightened Bribery Enforcement Under New Government
• Russian Sanctions and Uighur Import Regulations
• Data Protection Bill Changes Post-UK Election
• UK’s New Administration Faces Challenges and Changes
• Center-Ground Positioning in UK Politics

Resources:

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Tom Fox and Jonathan Armstrong, renowned expert in cyber security, co-host the award-winning Life with GDPR. Jonathan is on a short hiatus and in this episode, we have a special guest, Karen Moore who discusses the EU’s Corporate Sustainability-Due Diligence Directive.

Karen Moore is a well-versed professional in the area of impact assessments and due diligence, with a particular focus on human rights and environmental issues to prevent and address potential harm. Her perspective, shaped by her extensive experience, is that impact assessments and due diligence are key indicators of a corporation’s commitment to preserving the environment and upholding human rights.

Moore emphasizes the importance of these processes not only within a company’s own activities, but also within those of its suppliers and indirect suppliers. She stresses the need for a robust due diligence process, including tracking progress, publishing annual statements, implementing complaints procedures, and involving all employees.

Additionally, she highlights the challenges of managing these processes, such as complex questionnaires for third-party suppliers and the need for streamlined assessments. She believes in a proactive approach to corporate responsibility, going beyond regulatory requirements to foster sustainable practices and ethical decision-making.

 Key Takeaways:

• Ethical and Sustainable Business Practices Compliance Guidelines
• Ethical Evaluation for Data Privacy Compliance in the US
• Ethical Data Handling for GDPR Compliance
• Ethical Business Practices in Supply Chains

 Resources:

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Tom Fox and Jonathan Armstrong, renowned experts in cyber security, co-host the award-winning Life with GDPR. Today we consider the NIS2 Directive, which is the EU-wide legislation on cybersecurity. It provides legal measures to boost the overall level of cybersecurity in the EU.

Cybersecurity regulations are reshaping the landscape, demanding swift action and accountability from organizations and individuals. The NIS2 Directive tightens reporting deadlines, putting pressure on organizations to comply with cybersecurity incidents. This means that organizations need to be prepared to act quickly and efficiently in the event of a cyber incident to avoid penalties and maintain trust with their stakeholders. Management faces increased personal liability under the NIS 2 Directive, highlighting the need for proactive cybersecurity measures. This emphasizes the importance of implementing strong cybersecurity protocols and staying ahead of potential threats to protect both the organization and individual leaders from legal and financial repercussions.

Regulatory bodies advocate for a shift towards prevention in cybersecurity to combat rising cyber threats. This shift in focus underscores the importance of investing in proactive cybersecurity measures rather than simply reacting to incidents after they occur, ultimately leading to a more secure and resilient digital environment. Join Tom Fox and Jonathan Armstrong as they delve deeper into this topic on this episode of the Life with GDPR podcast.

Key Takeaways:

• NIS Two Directive: Stricter Reporting and Jurisdiction
• NIS Two Directive: Management’s Cybersecurity Liability
• Operational Resilience: Proactive Cybersecurity Measures

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Tom Fox and Jonathan Armstrong, renowned experts in cyber security, co-host the award-winning Life with GDPR. In this episode, they look at a breach of a big law.

In the wake of a recent spearphishing attack and data breach at a UK law firm, the legal community is abuzz with discussions on the responsibility of lawyers to prevent such attacks. Tom Fox, known for his critical perspective on big law firms, highlights the mistakes made by the firm in question, emphasizing the increasing concern over cyber-attacks targeting law firms and the need for timely reporting to regulatory authorities. Jonathan Armstrong, on the other hand, underscores the importance of proactive cybersecurity measures and timely reporting, commending the firm for taking immediate action but criticizing the delay in reporting the breach. Both Fox and Armstrong bring their unique perspectives shaped by their experiences in the field. Join them on this episode of the Life with GDPR podcast as they delve deeper into this topic.

Key Takeaways:

• A spearphishing Attack Leads to Data Breach
• Cybersecurity Measures for Law Firms
• The Power of Dedicated Data Protection Training

  Resources:

For more information on the issues raised in this podcast, check out the Cordery Compliance News Section. For more information on Cordery Compliance, go to their website here.

Also, check out the GDPR Navigator, one of the top resources for GDPR compliance, by clicking here. Check out the Cordery Data Breach Academy here.

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Tom Fox and Jonathan Armstrong, renowned experts in cyber security, co-host the award-winning Life with GDPR. In this episode, they look at the continued fallout from the Solar Winds data breach.

In the complex world of data protection, the General Data Protection Regulation (GDPR) has placed a spotlight on the importance of transparency, honesty, and corporate responsibility. Experts Tom Fox and Jonathan Armstrong bring their unique perspectives to this topic, shaped by their extensive experience in compliance and data protection. Fox emphasizes the potential legal consequences for corporate leaders who fail to disclose vulnerabilities or engage in dishonest practices, while Armstrong highlights the increasing pressure on individuals and corporations to disclose data breaches, with regulators focusing more on individual liability. Both stress the importance of transparency, the potential for litigation, and the role of whistleblowers.

Join Fox and Armstrong as they delve deeper into these issues on this episode of the Life with GDPR podcast.

Key Takeaways:

• The Importance of Truthfulness in GDPR
• The Importance of Transparency in Data Breaches
• Legal risks in data breaches and cybersecurity
• The Impact of Budget Constraints on Vulnerability Fixes

 Resources:

For more information on the issues raised in this podcast, check out the Cordery Compliance News Section. For more information on Cordery Compliance, go to their website here. Also, check out the GDPR Navigator, one of the top resources for GDPR Compliance by clicking here. Check out the Cordery Data Breach Academy here.

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Tom Fox and Jonathan Armstrong, renowned experts in cyber security, co-host the award-winning Life with GDPR. In this episode, they look at litigation over a data breach against Singtel Opus in Australia and the fallout from an investigation report.

The recent data breach at Intel Optus, affecting 1.2 million individuals, has brought to light the critical role of strategic communication in managing cybersecurity breaches. Tom and Jonathan Armstrong, offer their unique perspectives on this issue. Fox emphasizes the inevitability of cybersecurity breaches and the need for a comprehensive strategy, including effective communication, to manage them. He warns against the potential consequences of mishandling communication during a breach, such as jeopardizing insurance coverage.

Armstrong highlights the complexity of maintaining privilege in a global corporate structure and the importance of careful language to avoid invalidating insurance or causing unnecessary speculation. He also underscores the need for a holistic approach to cybersecurity, encompassing prevention, detection, remediation, and crisis communication. Join Tom Fox and Jonathan Armstrong as they delve deeper into this topic in the latest Life with GDPR podcast episode.

 Key Takeaways:

• Implications of Language in Data Breach Reporting
• Navigating CEO Communication and Insurance Coverage
• Navigating Insurance Coverage in Data Breaches

 Resources

For more information on the issues raised in this podcast, check out the Cordery Compliance, News Section. For more information on Cordery Compliance, go to their website here. Also check out the GDPR Navigator, one of the top resources for GDPR Compliance by clicking here. Check out the Cordery Data Breach Academy here. 

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Connect with Jonathan Armstrong

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