Privacy Disclosures

News & Analysis as of

Financial Institutions May Post Online Privacy Disclosures

The Consumer Financial Protection Bureau ("CFPB") recently amended Regulation P, which requires – in connection with the Gramm-Leach-Bliley Act – that financial institutions provide an annual disclosure of their privacy...more

New Option to Provide Annual Privacy Notices Online

CFPB Amends Regulation P to Permit Financial Institutions to Post Annual Privacy Notices Online in Lieu of Delivering Hard Copies to Customers - The Consumer Financial Protection Bureau (CFPB) has always touted itself...more

Some Gramm-Leach-Bliley Notices Can Now Be Posted Online

Some banks and other organizations covered under the Gramm-Leach-Bliley Act (GLBA) may now post their privacy policies online rather than having to mail them annually. Earlier this week, the Consumer Financial Protection...more

Privacy & Cybersecurity - May 2014

In This Issue: - EU Court of Justice Creates Broad Interpretation of the ‘Right to be Forgotten’ - White House Publishes Report on Risks and Opportunities Posed by ‘Big Data’ Practices - California AG...more

California's New How-to Guide for Privacy Policies

On Wednesday, the Attorney General of California released a new privacy guide, titled Making Your Privacy Practices Public. The guide doesn’t purport to be a restatement of California law (or other law) and expressly...more

CFPB extends comment period on privacy notice proposal

The CFPB is extending the comment period on its proposed rule that would amend Regulation P to allow financial institutions that satisfy certain conditions to deliver annual privacy notices to their customers using an...more

CFPB's Proposed Rule Promotes More Efficient and Effective Privacy Disclosures

The Consumer Financial Protection Bureau (CFPB) has proposed a rule that would promote more effective privacy disclosures from financial institutions to its respective customers. Currently, the Gramm-Leach-Bliley Act (GLBA)...more

New rules for biometric data

New rules on the usage of biometric data issued by the Italian data protection authority (the “Garante” or “DPA“) are meant to clarify the applicable obligations with the purpose to ease the adoption of technologies relying...more

Disclosures Need Not Contain Customers’ Actual Names to Violate the Video Privacy Protection Act Rules Hulu Court

In the latest of a string of victories for the plaintiffs in the Video Privacy Protection Act (VPPA) class action litigation against Hulu, LLC, the U.S. District Court for the Northern District of California ruled that Hulu’s...more

Hulu Video Privacy Protection Act Summary Judgment Ruling in the N.D. of California Emphasizes Importance of Knowing What Data...

On Monday, April 28, 2014, the Northern District of California in In Re: Hulu Privacy Litigation, No. 3:11-cv-03764-LB (M.J. Laurel Beeler), issued a summary judgment opinion under the Video Privacy Protection Act (“VPPA”),...more

Denied Again: Alleged Violation of Statute is Enough for Hulu Privacy Case to Proceed

On December 20, 2013, the U.S. District Court for the Northern District of California issued an order in In re: Hulu Privacy Litigation that solely addressed the issue of whether the Video Privacy Protection Act (the “VPPA”)...more

Hospital Disclosure of PHI to Media and Workforce Results in $275,000 Fine

HHS OCR announced today its second resolution agreement of 2013. Shasta Regional Medical Center (SRMC) has agreed to pay $275,000 and enter into a comprehensive corrective action plan (CAP) to settle an investigation opened...more

Burr Alert: Blowing The Cap Off Statutory Damages Under The FCCPA?: An Analysis Of Kahmeyer v. Federal Credit Corporation

In Kahmeyer v. Federal Credit Corporation, the 13th Judicial Circuit in Hillsborough County, Florida released an opinion that has given new life to the argument that each violation of the Florida Consumer Collection Practices...more

FTC Sets Guidelines for Mobile Privacy Disclosures

The FTC issued a new report, Mobile Privacy Disclosures: Building Trust Through Transparency, on February 1, 2013, detailing the Commission's recommendations for best practices for key players in the mobile "ecosystem":...more

FTC Releases Recommendations on Mobile Privacy Disclosures

On Friday, February 1, the Federal Trade Commission (FTC) released a staff report recommending best practices for mobile privacy disclosures. The report, available here, reviews the benefits and privacy risks of mobile...more

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