August 20, 2024 signaled the end of the California Privacy Protection Agency’s (CPPA) Notice of Proposed Regulatory Action (NPRA) comment period for Senate Bill 362, also known as the Delete Act (the “Act”)....more
9/11/2024
/ California Consumer Privacy Act (CCPA) ,
California Privacy Rights Act (CPRA) ,
Comment Period ,
Data Brokers ,
Minors ,
New Legislation ,
Personal Data ,
Proposed Regulation ,
Public Comment ,
Public Hearing ,
Registration Requirement ,
Reproductive Healthcare Issues
The early weeks of 2024 have seen continued activity on the state comprehensive privacy law front. Since our last update, at least 11 new comprehensive privacy bills have been proposed. In particular, Georgia, Hawaii,...more
2/23/2024
/ California Consumer Privacy Act (CCPA) ,
California Privacy Rights Act (CPRA) ,
Consumer Privacy Rights ,
COPPA ,
Data Controller ,
Data Privacy ,
FERPA ,
GLBA Privacy ,
Health Insurance Portability and Accountability Act (HIPAA) ,
Personal Information ,
Privacy Laws ,
Proposed Legislation ,
State Legislatures ,
State Privacy Laws
On January 8, 2024, the New Jersey Assembly and Senate passed Senate Bill 332 (S. 332, or the “Act”), and it was signed into law by Governor Phil Murphy on January 16. This makes New Jersey the first state to enact a...more
1/18/2024
/ California Consumer Privacy Act (CCPA) ,
California Privacy Rights Act (CPRA) ,
Data Processors ,
Data Protection ,
Effective Date ,
Enforcement ,
Enforcement Authority ,
Exemptions ,
Governor Murphy ,
Minors ,
New Legislation ,
Opt-Outs ,
Prior Express Consent ,
Privacy Laws ,
Sensitive Personal Information ,
State Attorneys General ,
State Privacy Laws
As we have detailed previously, 2023 was a landmark year for privacy law, featuring numerous developments at the federal, state and international levels, ranging from newly enacted statutes to massive regulatory enforcement...more
1/17/2024
/ Adtech ,
Artificial Intelligence ,
Audits ,
Biden Administration ,
Breach Notification Rule ,
California Consumer Privacy Act (CCPA) ,
California Privacy Rights Act (CPRA) ,
COPPA ,
Cybersecurity ,
Electronic Protected Health Information (ePHI) ,
Enforcement ,
Enforcement Actions ,
Executive Orders ,
Federal Trade Commission (FTC) ,
Health Insurance Portability and Accountability Act (HIPAA) ,
Popular ,
Privacy Laws ,
Proposed Legislation ,
Regulatory Requirements ,
Rulemaking Process ,
Sensitive Personal Information ,
State Privacy Laws
On December 8, the California Privacy Protection Agency (CPPA or “the Agency”) held a public Board meeting to discuss a range of topics, including proposed regulations on cybersecurity audits, risk assessments, and automated...more
In the run-up to this Friday’s December Board meeting, the California Privacy Protection Agency (CPPA or the “Agency”) has continued its recent flurry of regulatory activity. Late last week, the CPPA published an additional...more
12/7/2023
/ Audits ,
Automated Decision Systems (ADS) ,
Automated Systems ,
Board Meetings ,
California Consumer Privacy Act (CCPA) ,
California Privacy Protection Agency (CPPA) ,
California Privacy Rights Act (CPRA) ,
Cybersecurity ,
Data Subject Access Requests ,
Insurance Industry ,
Mobile Apps ,
Opt-Outs ,
Popular ,
Proposed Regulation ,
Risk Assessment ,
Sensitive Personal Information
In advance of the California Privacy Protection Agency’s (CPPA) December 8 Board meeting, the Agency has published new draft automated decisionmaking technology (ADMT) regulations, as well as revisions to draft regulations on...more
12/1/2023
/ Artificial Intelligence ,
Audits ,
Automated Decision Systems (ADS) ,
California Consumer Privacy Act (CCPA) ,
California Privacy Rights Act (CPRA) ,
Cybersecurity ,
Machine Learning ,
Notice Requirements ,
Opt-Outs ,
Personal Information ,
Right of Access ,
Risk Assessment
The state of California is on the verge of amending its current data broker law with Senate Bill 362, also known as the Delete Act (“the Act”). The Act passed in the Assembly’s Committee on Privacy and Consumer Protection and...more
9/1/2023
/ California Consumer Privacy Act (CCPA) ,
California Privacy Rights Act (CPRA) ,
Compliance ,
Consumer Privacy Rights ,
Data Brokers ,
Duty to Delete ,
Geolocation ,
Legislative History ,
Pending Legislation ,
PHI ,
Proposed Amendments ,
Registration Requirement ,
Right to Delete ,
Sensitive Personal Information
On July 14, the California Privacy Protection Agency (CPPA or the “Board”) hosted a meeting to discuss key issues. Notably, the Board’s New CPRA Rules Subcommittee (“the Subcommittee”) previewed three areas of forthcoming...more
8/9/2023
/ Advisory Board ,
Artificial Intelligence ,
Audits ,
Automation Systems ,
California Consumer Privacy Act (CCPA) ,
California Privacy Rights Act (CPRA) ,
Cybersecurity ,
Machine Learning ,
Personal Data ,
Personal Information ,
Proposed Regulation ,
Risk Assessment
On June 30, the Sacramento County Superior Court issued a ruling that will delay enforcement of regulations issued pursuant to the California Privacy Rights Act (CPRA) to March 29, 2024. These regulations were originally...more
7/11/2023
/ Audits ,
California Consumer Privacy Act (CCPA) ,
California Privacy Rights Act (CPRA) ,
Chamber of Commerce ,
Compliance Dates ,
Covered Entities ,
Enforcement ,
Grace Period ,
Risk Assessment ,
State Privacy Laws ,
Statutory Requirements ,
Time Extensions
On Wednesday, March 15, the Colorado Attorney General’s Office announced the finalization of the Colorado Privacy Act Rules (“Rules”). The Rules implement the Colorado Privacy Act (CPA), a comprehensive privacy law enacted in...more
On Friday, March 3, 2023, the California Privacy Protection Agency (CPPA) held a public board meeting. Though the meeting focused primarily on the Agency’s budget and various administrative issues (e.g., subcommittee...more
3/13/2023
/ Administrative Review ,
Audits ,
Board Meetings ,
California Consumer Privacy Act (CCPA) ,
California Privacy Protection Agency (CPPA) ,
California Privacy Rights Act (CPRA) ,
Cybersecurity ,
Proposed Legislation ,
Public Comment ,
Risk Assessment ,
Rulemaking Process
In addition to the numerous comprehensive privacy laws that have been proposed in at least 20 states thus far in 2023, legislative trends demonstrate an emerging focus on regulations that address specific types of...more
On Friday, February 3, 2023, the California Privacy Protection Agency (CPPA) held a public board meeting at which it voted unanimously to (1) approve the final text of the California Privacy Rights Act (CPRA) regulations and...more
2/9/2023
/ Artificial Intelligence ,
Audits ,
Board Meetings ,
California Privacy Rights Act (CPRA) ,
Comment Period ,
Compliance ,
Cybersecurity ,
New Regulations ,
NPRM ,
Public Meetings ,
Regulatory Agencies ,
Regulatory Agenda ,
Risk Assessment
On September 30, the Colorado Attorney General’s Office (“Colorado AG’s Office”) released proposed rules (the “Proposed Rules”) for the Colorado Privacy Act (CPA), which goes into effect on July 1, 2023. The Proposed Rules...more
On July 20, the House Committee on Energy & Commerce held an open markup session on the American Data Privacy and Protection Act (ADPPA), which concluded in an affirmative vote (53-2) for an amended version of the bill to...more
As a follow-up to their release of draft regulations (“Draft Regulations”) for the California Privacy Rights Act (CPRA) (which we covered in this article), the California Privacy Protection Agency (“Agency”) released an...more
The California Privacy Protection Agency (CPPA) recently released draft regulations for the California Privacy Rights Act (CPRA) (Draft Regulations). These Draft Regulations come roughly two months before the agency is...more
On May 27, 2022, the California Privacy Protection Agency (CPPA) released draft regulations for the California Privacy Rights Act (CPRA) (Draft Regulations). The Draft Regulations come roughly two months before the agency is...more
On April 19, 2022, the Better Business Bureau’s (BBB) Center for Industry Self-Regulation introduced the TeenAge Privacy Program (TAPP), an emerging initiative that sets out to help companies develop a teen-centric approach...more
5/4/2022
/ Behavioral Advertising ,
Better Business Bureau ,
California Consumer Privacy Act (CCPA) ,
California Privacy Rights Act (CPRA) ,
Consent ,
COPPA ,
Data Retention ,
Data-Sharing ,
Federal Trade Commission (FTC) ,
Online Advertisements ,
Online Platforms ,
Parental Consent ,
User-Generated Content
In our third California Privacy Update, we continue to closely follow potential privacy law updates in California. ...more
On March 29 and March 30, 2022, the Board of the California Privacy Protection Agency (CPPA or “Agency”) conducted informational sessions on the California Privacy Rights Act (CPRA) and allowed public comment on its...more
In our second California Privacy Update, we continue to closely follow updates in California privacy law, especially those to the California Privacy Rights Act (CPRA). Below are the recent updates to the California’s privacy...more
The California Consumer Privacy Act (CCPA) may seem like old news, especially now that Virginia and Colorado have also passed comprehensive privacy laws, but businesses must continue to pay attention to California if they...more
On June 7, 2021, the Colorado House of Representatives passed the Colorado Privacy Act (CPA), a comprehensive privacy law similar to the California Privacy Rights Act (CPRA) and California Consumer Privacy Act (CCPA), as well...more
6/9/2021
/ Business Associates ,
California Consumer Privacy Act (CCPA) ,
California Privacy Rights Act (CPRA) ,
Covered Entities ,
Data Controller ,
Data Privacy ,
Exemptions ,
General Data Protection Regulation (GDPR) ,
Health Insurance Portability and Accountability Act (HIPAA) ,
Opt-Outs ,
Pending Legislation ,
Personal Data ,
Sensitive Personal Information ,
State Privacy Laws