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Information Commissioner's Office (ICO) Enforcement Actions

Dechert LLP

Dechert Cyber Bits - Issue 56

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SEC Fines the New York Stock Exchange’s Parent Company $10 million for Failure to Promptly Notify Its Subsidiaries of Cybersecurity Breach - On May 22, 2024, the Securities and Exchange Commission (“SEC”) imposed a $10...more

Skadden, Arps, Slate, Meagher & Flom LLP

The UK ICO Publishes Its Strategy on AI Governance

Rather than specifically regulating artificial intelligence (AI), the UK government has opted to rely on the existing web of laws and regulations applying to technology across a spectrum of sectors in its jurisdiction. But...more

McDermott Will & Emery

European Regulators Provide Some Key Clarifications on Cookie Banners

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The European Data Protection Board (EDPB) adopted a draft report of the work undertaken by the Cookie Banner Taskforce (the Report). The Report describes how regulators apply cookie legislation in handling certain types of...more

BCLP

UK Children’s Privacy Protection Comes of Age

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The Age Appropriate Design Code (“AADC”) - more commonly known as the Children’s Code - has been heralded as the world’s first code to protect children online. Compliance with the AADC became mandatory for in-scope businesses...more

Morrison & Foerster LLP

SEC To LBRY: “You’re Overdue.” Recent Enforcement Action Highlights Evolving SEC Focus On Decentralization

“Decentralization” is a concept that has consistently vexed the entire blockchain-enabled ecosystem in the U.S., including its counsel and regulators, wherein a lack of clarity on the exact definition of decentralization has...more

Kramer Levin Naftalis & Frankel LLP

ICO and CNIL Levy Landmark Fines Against British Airways and Marriott for 2018 Data Breaches

On Oct. 30, 2020, the United Kingdom’s data protection authority, the Information Commissioner’s Office (ICO), in connection with France’s Commission nationale de l’informatique et des libertés (CNIL), announced the largest...more

BCLP

Cyber Security Trends: Tips from recent UK enforcement activity - Part 4

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When the regulator has decided to investigate your organisation following a data breach, the remit for the investigation will be wide-ranging and go beyond the narrow circumstances of the breach. Recent decisions shed useful...more

Akin Gump Strauss Hauer & Feld LLP

U.K.’s Data Protection Regulator’s Updated Guidance on “Empathetic and Pragmatic” Approach

On April 15, 2020, the Information Commissioner’s Office (ICO), the U.K.’s data protection authority, issued further guidance on its regulatory approach during the global COVID-19 pandemic. Following its March note that we...more

BCLP

Cyber Security Trends: Tips from recent UK enforcement activity – Part 3

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Key to recent ICO decisions has been the ICO’s assessment of the extent and quality of communications with affected individuals and the regulator itself. It is clear the ICO sees certain behaviours (such as the setting up of...more

BCLP

Cyber Security Trends: Tips from recent UK enforcement activity – Part 2

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In this part of our briefing series, we cover how prior regulatory enforcement action affects the assessment of sanctions and some pitfalls associated with undertaking internal security audits.  Who is this relevant for?...more

Orrick, Herrington & Sutcliffe LLP

ICO Fines: When Is An Appeal Appealing?

The decision to appeal a regulatory finding is never taken lightly. By the time a regulator has completed its investigation and notified a company of its intention to fine, the company will have invested significant time and...more

BCLP

Cyber Security Trends: Tips from recent UK enforcement - Part 1

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What insights into cyber security norms can organisations glean from the UK ICO’s recent enforcement decisions, most of which have been released since the GDPR came into force? Final fines are still awaited on the UK’s...more

Morrison & Foerster LLP

UK Enforcement Actions Underscore The Importance Of Due Diligence When Using Third-party Marketing Providers

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Recent UK enforcement actions highlight the risks to companies of relying on third-party providers to obtain marketing consents from individuals on their behalf. A claims management company has been separately fined by both...more

Latham & Watkins LLP

High GDPR Fines: German Data Protection Authority Joins the Club

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Following in the footsteps of the CNIL and the ICO, the Berlin DPA will impose a multimillion-euro fine for breach of the GDPR. The Berlin Data Protection Authority (Berlin DPA) recently announced that it will issue a...more

Latham & Watkins LLP

Britische Datenschutzaufsicht ICO kündigt Rekordbußgelder wegen DSGVO-Verstößen an

Latham & Watkins LLP on

Das ICO kündigt an, Bußgelder gegen British Airways und Marriott zu verhängen. Was ist passiert, wie geht es weiter? Am 8. Juli 2019 kündigte das Information Commissioner’s Office (ICO) an, gegen British Airways wegen...more

Proskauer on Privacy

ICO Issues First Intentions to Fine Under the GDPR

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GDPR fines are seemingly like buses, you wait over a year for enforcement action by the UK’s data supervisory authority, the ICO, and then two come along at once – and with quite dramatic effect. The ICO has stretched its...more

Shook, Hardy & Bacon L.L.P.

Privacy and Data Security Alert | July 2019 #2

British Data Protection Authority Flexes GDPR Enforcement Muscles - No longer is the bark of sanctions for lax data protection practices worse than its bite. The Information Commissioner’s Office (ICO)—the United Kingdom's...more

Sheppard Mullin Richter & Hampton LLP

UK’s ICO Brings Texting Enforcement Action, Fines Vote Leave 40,000 Pounds

Prior to the “Brexit” vote in 2016, the pro-Brexit campaign, Vote Leave, sent almost 200,000 unsolicited texts in violation of the Privacy and Electronic Communications Regulations (PECR), according to a recent settlement it...more

Sheppard Mullin Richter & Hampton LLP

Talk About Ironic: Brexit Group Fined Under EU-Related Privacy Regulations

In an ironic twist, the British Information Commissioner’s Office (ICO) recently fined a Brexit advocacy group for violating regulations issued under an EU directive. The fines, totaling £120,000, were levied against...more

Katten Muchin Rosenman LLP

The Sky's the Limit: The Cathay Pacific and British Airways Data Hacks, and the GDPR Six Months On

Cathay Pacific, the Hong Kong airline, is the latest airline to face a cyber-attack; in this case, one that has resulted in the theft of personal data of up to 9.4 million passengers. The hackers gained "unauthorised access"...more

Sheppard Mullin Richter & Hampton LLP

UK Issues Fine for Unsolicited Funeral Marketing Emails

The U.K. data protection authority recently fined a lead generation company £90,000 ($118,000) for a 2017 unsolicited email marketing campaign. The company, Boost Finance Ltd, sent over 4 million emails promoting pre-paid...more

A&O Shearman

US Securities and Exchange Commission Halts Fraudulent Initial Coin Offering

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The Securities and Exchange Commission announced that it halted a planned initial coin offering and related pre-ICO sales by Blockvest LLC and its founder, Reginald Buddy Ringgold, III. In seeking an emergency court order,...more

Latham & Watkins LLP

SEC Charges “ICO Superstore” as Unregistered Broker-Dealer

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The settled order is the first SEC action charging a seller of digital tokens as an unregistered broker-dealer. On September 11, 2018, the U.S. Securities and Exchange Commission (SEC) announced a settled order instituting...more

Katten Muchin Rosenman LLP

Bridging the Weeks - June 2018

The chief executive officer of a major worldwide banking group agreed to pay the equivalent of US $870,000 as fines to two United Kingdom regulators, and had the equivalent of US $677,000 of prior pay clawed back by his...more

Jones Day

Global Privacy & Cybersecurity Update Vol. 14

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New York Attorney General Announces Record Number of Data Breach Notices in 2016 - On March 21, 2017, the New York Attorney General's Office announced that it received 1,300 reported data breaches in 2016—a 60 percent...more

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