Extending Cybersecurity Breach Notice Requirements to Intelligence Community Contractors

David Fagan, Susan Cassidy, and Catlin Meade write:

As an indicator of the continuing focus of government authorities on cybersecurity breaches and potential notification requirements, certain contractors for the federal government may soon face new rapid reporting requirements for successful network penetrations.  Specifically, President Obama signed the 2014 Intelligence Authorization Act (“2014 IAA”) into law on July 7, 2014, starting a 90-day clock under Section 325 of the Act for the Director of National Intelligence (“DNI”) to promulgate regulations for “cleared intelligence contractors” to report the successful penetration of their networks and information systems.

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