NIST Cybersecurity Framework 2.0 Released For Public Comment

On August 8, 2023, the National Institute of Standards and Technology (NIST) released the initial draft of its Cybersecurity Framework 2.0 and draft Implementation Examples for public comment. This marks the first significant update to the NIST Cybersecurity Framework ("Framework") since its initial release in 2014, which is intended to address current and future cybersecurity threats of all organizations and to make it easier for organizations to use the Framework. An updated Framework is important given that the Federal Trade Commission (the "FTC") has routinely relied upon the existing Framework in determining whether a company's data security practices are reasonable and not unfair or deceptive in violation of Section 5 of the FTC Act.