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The framework applies to all property or casualty insurers that write cybersecurity insurance. However, the DFS wants all insurers, even though those that don't offer cybersecurity insurance, to "still evaluate their exposure to 'silent risk' and take appropriate steps to reduce that exposure."
The GDPR provision that may keep IT security teams busiest is Article 32, which requires “a process for regularly testing, assessing and evaluating the effectiveness of technical and organizational measures for ensuring the security of the processing” of personal data. Financial Data Protection Laws.
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