Insights & Resources

The New York SHIELD Act has gone into effect today (October 23, 2019) and entities that maintain electronic information regarding New York residents will need to ensure compliance. At the very least, for entities that have HIPAA compliance programs, this will mean that each entity’s HIPAA breach policy will need to be updated and the revised policy implemented.  For entities that do not have HIPAA compliance programs this may also mean that administrative, technical and physical safeguards need to be developed.  In addition, for all entities, there are a number of new reporting considerations when there is an intrusion (e.g., a hack, ransomware, phishing attack) or unauthorized access into an entity’s electronic systems.