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The Federal Trade Commission (FTC) is updating the requirements for organizations to establish a reasonable cybersecurity program, with revised recommendations involving internal actions of a company—like designating a chief information security officer (CISO) who will report on cybersecurity, at least annually, to the board of directors. This suggestion is neither new nor novel, and closely mirrors regulation released by the New York Department of Financial Services (NYDFS). Some of the biggest changes, however, reflect external actions and partners.


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