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Compliance Into the Weeds

Blackbaud – Failures in Cyber Breach Disclosures

The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we discuss the consequences of insufficient disclosure regarding cybersecurity risks, as demonstrated in the recent Blackbaud SEC enforcement action. The SEC requires companies to proactively disclose material events, and the Delaware Court of Chancery is making it clear that senior executives are responsible for ensuring compliance with disclosure requirements. Tune in next week to hear more Compliance into the Weeds from Tom and Matt. 

Key Highlights

·      The cost of poor communication: $3 million lesson from Blackbaud’s FCC fine.

·      Disclosure Controls and the Sarbanes Oxley Act

·      The Consequences of Failing to Comply with the SEC and FCC Regulations on Reporting Data Breaches

·      SEC Cracking Heads and What’s Next 

Notable Quotes:

1.      “Do words still matter? I think that they do.”

2.     “I couldn’t think of at least 3 million reasons why that was a bad idea in hindsight, and maybe they should have been more forthcoming.”

3.      “Oh, well, actually, you know, we missed the revenue target, but we forgot to tell the CFO people would be fired. You know, there would be heads stuck on the pikes. In front of the office lobby or something like that.”

4.     “A compromise of our data security that results in customer or donor personal or payment card data being obtained by unauthorized persons could, and that’s the word. Could adversely affect our reputation with our customers and others.”

 Resources

Matt  on LinkedIn

Matt on Radical Compliance

Tom

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