Incident Response and Data Retention Protocols at Center of NYDFS Enforcement Action Against Delta Dental

On April 30, the New York State Department of Financial Services (“NYDFS” or the “Department”) announced a $2.25 million settlement with Delta Dental Insurance Company and Delta Dental of New York, Inc. (an accident and health insurer and non-profit dental expense indemnity, respectively) (collectively, “Delta Dental” or the “Company”) for alleged violations of NYDFS’s cybersecurity regulation (23 New York Codes, Rules and Regulations (“NYCRR”) Part 500, also known as the “Part 500 Regulation”).