In a previous post, we discussed how to
manage cyber security risks during the negotiation and due
diligence stages of an M&A transaction. In this post, we
discuss the ways regulatory bodies have begun managing these risks
and the significance of these efforts to M&A participants
engaging in substantial data asset transfers.
On February 18, 2016, the Investment Industry Regulatory
Organization of Canada (IIROC) released its
Compliance Priorities Report. Following this, in March 2016, the
Ontario Securities Commission (OSC) released its
Draft Statement of Priorities for 2016/2017. These reports, which
constitute summaries of issues and action plans identified by the
regulators, share a common focus on the systemic risks posed by
insufficient cyber-security and recognize that our growing
dependence on digital connectivity enhances exposure to
cyber-attacks.