Blogs

New SEC Disclosure Guidance About Cyber Security Risks

11.08.11

The SEC recently issued new disclosure guidance about cyber security risks.  Peter Vogel’s Internet, Information Technology, & e-Discovery Blog last week featured a guest blog on the new guidance by James F. Brashear, Vice President, General Counsel and Corporate Secretary of Zix Corporation (NASDAQ:  ZIXI).  (Peter Vogel is a partner with Gardere Wynne Sewell LLP.)

In addition to summarizing the new guidance, Mr. Brashear includes a list of questions that are intended to prompt a discussion—in a company’s disclosure committee and otherwise—about changes in cyber security risks and to help create a written record for management’s consideration of cyber risks.

OUR TAKE:  The new guidance is consistent with the increasing emphasis on risk assessment and management by both a company’s management and board of directors.  In this case, it is tightly focused on an area that is likely to affect almost every company, which will increasingly be important in our increasingly technological world.

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