NY Shield Act Data Security Requirements Effective This Month

Businesses collecting personal information from New York residents will soon be expected to apply enhanced data security requirements. The New York SHIELD Act, signed into law in July 2019, expanded breach notice requirements in October 2019. Now, On March 21, 2020, the remaining provisions related to data security will also come into effect. As we wrote previously, businesses subject to the law must implement data security programs that include at least the following:

• Reasonable administrative safeguards, including: designate one or more employees to coordinate the security program; identification of internal and external risks and safeguards to control the risks; train employees on security practices; select service providers capable of maintaining appropriate safeguards (and contractually require said safeguards);