Jonathan G. Cedarbaum is a Partner in the Government and Regulatory Litigation and Privacy, Information Security and Communications Groups at WilmerHale. Elijah Alper is a Senior Associate in WilmerHale's Financial Institutions Group. Both are based in WilmerHale's Washington, DC office.

The large-scale data breaches at Target, Neiman Marcus and eBay are only three of the most visible examples of the growing importance of privacy and data security to the payments system. As firms in the financial sector and the broader payments systemand their vendorshave become more and more dependent on digital methods of storage and transmissions of information, protecting that information, from both external attack and internal loss, has increasingly become a high priority of senior management and boards of directors. Regulatory agencies in turnat the state and federal levels, as well as in other countrieshave greatly increased their focus on companies' privacy and data security practices, both as they may affect consumers and as they may influence companies; financial soundness.

Originally published in Fintech Law Reports, Thomson Reuters, May/June 2014

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