Simply working in chronological order based on compliance dates may not be the best way to start.
Individuals who are fully covered under a firm’s program are broadly exempt.
The actual drafting of the program should be done in steps. It becomes another plan for the organization, comparable to sales, marketing and other plans that collectively drive the business and shape the work environment.
It's possible to obtain exemption from some of the regulation’s requirements.
By February 15, 2018, every New York licensee must certify compliance with the state's cybersecurity regulations.