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Two’s Company: Virginia Has a Comprehensive Data Privacy Law

On March 2, Governor Ralph Northam signed the Virginia Consumer Data Protection Act (VCDPA) into law, making Virginia the second state to enact comprehensive privacy legislation. With the VCDPA on the books, companies have...more

State Privacy Bills Gain Momentum

In the absence of comprehensive federal privacy law, states are following California’s lead and proposing their own privacy bills. This blog post provides an overview of three state bills that we are tracking closely in this...more

CCPA Litigation Round-Up: Q3 & Q4 2020

It has been a full year since the California Consumer Privacy Act (“CCPA”) took effect at the top of 2020. In the cases filed in the second half of the year, the complaints more frequently assert a violation of the CCPA as a...more

Consumer Litigation Under the CCPA: A Year in Review

Private consumer litigation in 2020 was significantly impacted by the California Consumer Privacy Act (CCPA) which took effect on January 1, 2020. Whether asserted as a standalone CCPA violation claim or as a predicate act...more

CCPA Update: California AG Proposes Fourth Set of Changes to CCPA Regulations

The California Attorney General’s office announced a fourth set of proposed modifications to the CCPA regulations. These modifications: (1) clarify the requirement for businesses that sell personal information that is...more

Filling in the Holes: Dunkin Settles Breach Allegations with NYAG

On Tuesday, the New York Attorney General Letitia James announced a settlement with Dunkin’ Brands, Inc. over allegations that the company failed to adequately respond to years of cyberattacks that compromised customers’...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

Tackling the Privacy, Data Security, and Employment Issues Related to Returning to Work

Coronavirus testing and screening procedures are central to many companies’ return-to-work plans. Because testing and screening data is often sensitive and may help to determine whether individuals are allowed to work,...more

District Court Affirms Need to Turn Over Data Breach Report

Earlier this month, we offered our analysis and takeaways from a Magistrate Judge’s decision that defendant Capital One was required to produce a third-party data breach assessment report as part of ongoing consumer...more

Lessons Learned for Maintaining Attorney-Client Privileged Data Breach Investigation (and other Consultant) Reports

Following a data breach, companies generally launch an investigation to determine the source and scope of the breach. These efforts are often led by in-house privacy, compliance, and/or litigation counsel with an eye firmly...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

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

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

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

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

New Jersey Amps Up Focus on Privacy and Cybersecurity

California is not the only state focused on privacy. The New Jersey Attorney General’s Office recently emphasized how the Office is prioritizing its enforcement of such issues. Over its first year, the newly-created Data...more

Be Careful What You Say About the CCPA

As privacy and personal data issues continue to be a focus of both legal action and media coverage, privacy policy statements are getting dusted off and reviewed by more eyes. Imprecise or inaccurate policy statements,...more

CCPA Update: Prioritizing Compliance with Two Months Until the CCPA Takes Effect

In exactly two months, the California Consumer Privacy Act (CCPA) takes effect. Many businesses are devoting resources to timely comply, but between the late rollout of the Attorney General’s draft regulations, recent...more

CCPA Draft Regulations: What to Know About Timing and Process

With the new CCPA draft regulations out, you may be wondering—how can I comment? What are the deadlines? When will the draft regulations be finalized and go into effect? This blog post summarizes the process and timing for...more

CCPA Update: California Governor Signs Seven Amendments to the CCPA

On Friday, California Governor Gavin Newsom signed seven legislative proposals to amend the California Consumer Privacy Act (CCPA), marking the end of a nearly-yearlong process to make changes to the new privacy law before it...more

CCPA Update: California Attorney General Issues Draft Privacy Rules

On Thursday, California Attorney General Xavier Becerra released draft regulations implementing the California Consumer Privacy Act (CCPA). The regulations provide the first glimpse into how the Attorney General interprets...more

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