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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

TCPA FCC Petitions Tracker - April 2020

Kelley Drye’s Communications Practice Group presents this tracker of active Telephone Consumer Protection Act (“TCPA”) petitions before the Federal Communications Commission (“FCC”). With the recent increase in litigation...more

FCC/FTC Stake out Aggressive Robocall Position, Tell Gateway VoIP Providers to Block COVID-19 Robocalls – or Be Blocked Themselves

The FTC and FCC have taken a number of actions to stem unlawful robocalls generally and, during the COVID-19 pandemic, to stem harmful and deceptive calls that seek to exploit the COVID-19 crisis. Even amid the backdrop of...more

FTC Guidance on AI: Don’t Surprise Consumers – Or Yourself

FTC Bureau of Consumer Protection Director Andrew Smith this week published some helpful pointers for companies that are developing or using AI to support consumer-facing services. These pointers are drawn from past FTC...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 Litigation Round-Up

The California Consumer Privacy Act (CCPA) took effect January 1, 2020. While the California Attorney General’s enforcement authority is delayed until July 1, private litigants have already started to file direct claims...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

States Place New Restrictions on Collection Efforts and Outbound Calls Amidst COVID-19 Pandemic

The COVID-19 pandemic continues to have far-reaching effects on businesses and consumers everywhere. While many states are taking broadly consistent approaches on certain issues (e.g., price gouging, non-essential business...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

Telemarketing During the Pandemic

Over the past few weeks, my colleagues have discussed some of the considerations for marketing around COVID-19, including claim substantiation and price gouging. ...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

TCPA FCC Petitions Tracker - March 2020

Kelley Drye’s Communications Practice Group presents this tracker of active Telephone Consumer Protection Act (“TCPA”) petitions before the Federal Communications Commission (“FCC”). With the recent increase in litigation...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

TCPA FCC Petitions Tracker - February 2020

Kelley Drye’s Communications Practice Group presents this tracker of active Telephone Consumer Protection Act (“TCPA”) petitions before the Federal Communications Commission (“FCC”). With the recent increase in litigation...more

What Does Brexit Mean for Privacy Shield?

Three and a half years after UK citizens voted to leave the EU, the country officially left the Union on January 31. One of the many questions resulting from the departure is what happens to the EU-U.S. Privacy Shield as it...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 Eleventh Circuit Weighs In On ATDS Definition

In Glasser v. Hilton Grand Vacations Company, LLC, the Eleventh Circuit addressed a pair of appeals that presented the question of the appropriate definition of an automatic telephone dialing system (“ATDS”) as set forth in...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

TCPA FCC Petitions Tracker - January 2020

Kelley Drye’s Communications Practice Group presents this tracker of active Telephone Consumer Protection Act (“TCPA”) petitions before the Federal Communications Commission (“FCC”). With the recent increase in litigation...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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