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California AG Proposes Changes to CCPA Regulations

Only two months after finalizing the CCPA regulations, the California Attorney General’s office today released a new set of proposed changes, most significantly addressing “Do Not Sell My Personal Information” requests. The...more

California Privacy Legislation Round-Up: Gov. Newsom Signs CCPA Employee Exemption Extension, Vetoes Others

Prior to the September 30 deadline to sign or veto legislation, California Governor Gavin Newsom recently took action on three bills related to data privacy. Bringing some potential certainty to the dynamic CCPA landscape,...more

CCPA Update: California Legislature Votes to Extend Employee and B2B Exemptions; Awaits Governor’s Signature

On August 30th, the California legislature passed a bill to continue the employee and business-to-business (B2B) exemptions contained in the CCPA for another year. Currently, the CCPA provides two limited exemptions for...more

CCPA Privacy Regulations Are Approved and Effective Immediately

The California Office of Administrative Law today approved the CCPA Regulations that the California Attorney General submitted in June, and the regulations are effective immediately. As we discussed here, the now-final...more

NY Department of Financial Services Announces First Enforcement Action Under Cybersecurity Regulation

On July 22, the New York Department of Financial Services (DFS) announced the first enforcement action under its new Cybersecurity Regulation, which requires that businesses registered or licensed by DFS comply with a number...more

CCPA Litigation Round-Up: Q2 2020

January 1, 2020 was the effective date for the California Consumer Privacy Act (CCPA). As we reported and summarized in our Q1 2020 CCPA Litigation Round-Up, private litigants wasted no time in filing consumer-related causes...more

EU Court of Justice Strikes Down Privacy Shield; SCCs Safe for Now

On July 16, the European Court of Justice (CJEU) issued a highly-anticipated decision evaluating the validity of two popular mechanisms for transferring personal data from the EU to the United States: Privacy Shield and...more

CCPA 2.0 Gets Closer to Reality: CPRA Eligible for November 2020 Ballot; How Does it Compare to CCPA?

On June 24, 2020, the Secretary of State of California announced that the California Privacy Rights Act (CPRA), had enough votes to be eligible for the November 2020 general election ballot. CPRA is a ballot initiative,...more

CCPA Update: Final Regulations Submitted but No Changes from Prior Draft

On June 2, California Attorney General Xavier Becerra announced that he had submitted final CCPA regulations to the Office of Administrative Law (OAL) for review. The final regulations are substantively identical to the...more

Democrats Release Their Own COVID-19 Privacy Legislation

Following the Republican-sponsored COVID-19 Consumer Data Protection Act of 2019, Democratic legislators recently introduced the Public Health Emergency Privacy Act. Senators Richard Blumenthal and Mark Warner of Connecticut...more

Senate Republicans Release COVID-19 Privacy Bill

In light of concerns associated with attempts to use personal data to track the spread of COVID-19, a group of Republican Senators, led by Mississippi Senator Roger Wicker, introduced the COVID-19 Consumer Protection Data Act...more

The CCPA Non-Discrimination Right, Explained

The California Consumer Privacy Act (CCPA) provides consumers with a right to non-discrimination when they exercise other privacy rights guaranteed by the law, such as the right to access, delete, or opt out of the sale of...more

Arbitration of CCPA Claims

Recent putative consumer class action cases filed against Ring and Zoom raise allegations under the California Consumer Privacy Act (“CCPA”) and are likely to be the first battlegrounds over the CCPA’s potential hostility to...more

No Delay? What To Expect on CCPA Enforcement Timing

The CCPA grants the California Attorney General (AG) the authority to enforce the CCPA starting on July 1, 2020. Last month, the AG confirmed no intention to delay that enforcement date due to the COVID-19 pandemic, despite...more

In Non-COVID-19 News, New York SHIELD Act Takes Effect

Effective March 21, 2020, the New York SHIELD Act imposes data security requirements on most businesses that own or license computerized data that includes the “private information” (defined below) of New York residents. In...more

Data Privacy Considerations for Coronavirus Data Tools

Data is helping governments, researchers, and companies across the world track the spread of the novel coronavirus, monitor cases and outcomes of COVID-19, and devise ways to halt the virus’s spread. As part of these...more

Facial Recognition Tech Enforced by Vermont AG Under State Privacy & Data Broker Laws

Vermont Attorney General Thomas Donovan Jr. has ratcheted up ongoing scrutiny of facial recognition technology. On March 10, the Vermont AG sued facial recognition technology provider Clearview AI and moved for a preliminary...more

CCPA Update: Attorney General Releases Third Draft of Proposed CCPA Regulations

On Wednesday, the California Attorney General (AG) released a third draft of proposed CCPA regulations for public comment. The draft contains a series of technical corrections, along with a handful of substantive incremental...more

CCPA Update: Attorney General Proposes Modified Draft Regulations

On Friday, California Attorney General Xavier Becerra released proposed modifications to the formerly-released draft regulations implementing the California Consumer Privacy Act (CCPA). The modifications reflect the Attorney...more

The U.S. Approach to Privacy: What Is It, and Where Is It Headed?

As we mark Data Privacy Day, today is a good time to take stock of where U.S. privacy legislation stands in relation to the developments of the past few years. In less than two years, the GDPR and the CCPA became the most...more

CCPA Update: Data Broker Registry Now Live

The California Attorney General unveiled its data broker registry on Monday. On or before January 31st, companies qualifying as a “data broker” based on the prior year’s activities are required to register their name and...more

CCPA Implementation: An Early Map

The January 1, 2020 effective date of the California Consumer Privacy Act (CCPA) has come and gone, but questions about how to comply with the law show no hint of disappearing. As companies move past their efforts to comply...more

CCPA Marathon: January 1 Might Be the Midway Point

Congratulations. You’re nearly to January 1 with new practices designed to address CCPA obligations. Hydrate, and grab an energy bar – you’re just hitting your stride. Up ahead, we’ll need to incorporate obligations under the...more

Potential Constitutional Challenges to the CCPA

When it takes effect next month, the CCPA is almost certain to become an immediate spark for litigation. While requests for access/deletion and individual or threatened claims start to fill in-house legal departments’...more

A National Federal Privacy Law? Check Out COPRA, The Most Comprehensive Privacy Bill Introduced Yet

On November 26, 2019, Senator Maria Cantwell (D-WA) along with other Democratic senators across four key Senate committees introduced the Consumer Online Privacy Right Act (“COPRA”). Per Senator Klobuchar’s description,...more

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