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CISA and JCDC Conduct First-Ever Public-Private AI Security Incident Tabletop Exercise

On June 13, 2024, the Cybersecurity and Infrastructure Security Agency (CISA) collaborated with the Joint Cyber Defense Collaborative (JCDC) to hold the federal government’s first tabletop exercise for “AI security...more

Data Breach Notification Requirements Under the Safeguards Rule Now in Effect

For years, the Gramm-Leach-Bliley Act (GLBA) has required financial institutions to maintain reasonable safeguards for consumer data, but has only had limited breach-reporting requirements. To the extent financial...more

China Releases Updated Regulations on Permits Needed for Transferring Data out of China

On March 22, 2024, the Cyberspace Administration of China (CAC) published the Regulations on Promoting and Regulating Cross-border Data Flow (the “Regulations”), effective immediately. The Regulations supplement China data...more

White House Executive Order to Regulate Transactions Involving Sensitive Personal Data of Americans

The White House announced that President Biden will sign an executive order designed to protect sensitive data of U.S. persons from exploitation by identified countries of concern.  This executive order is expected to be...more

FTC Launches Investigation into Creator of ChatGPT

In mid-July, the Federal Trade Commission (FTC) reportedly opened an investigation into OpenAI, the maker of ChatGPT, sending the company an extensive Civil Investigative Demand (CID). While FTC investigations are normally...more

Germany’s Cyber Threat Landscape – Top 3 Lessons from the BKA Situation Report

Germany boasts one of the world’s largest, most sophisticated, and international economies. Companies doing business in Germany are thus an increasingly relevant target for cyberattacks....more

FTC Guidance Creates New Breach Notification Obligations

The Federal Trade Commission has issued new guidance under which consumers or companies should be notified of data breaches “regardless of whether a breach notification law applies.” Our Consumer Protection/FTC Team analyzes...more

Swiss Data Protection Regulator Is Latest to Outline Framework for Transferring Data to the SEC

Entities registered with the U.S. Securities & Exchange Commission (SEC) must maintain certain books and records and can be subject to the SEC’s examination, inspection, and enforcement authority. Responding to SEC requests...more

A CCPA Private Right of Action on the Horizon: Class Action Complaints Test Whether Plaintiffs Can Sue for Any Violation of the...

Plaintiffs’ counsel have started to lay the groundwork for a broad private right of action under the California Consumer Privacy Act (CCPA). The first part of this article provides an overview of how the CCPA addresses...more

California Attorney General Issues Second Round of Modifications to CCPA Regulations

At approximately 6:00 p.m. today, March 11, 2020, California Attorney General Xavier Becerra announced a second round of modifications to the draft regulations his office is preparing for the California Consumer Privacy Act...more

The Updated CCPA Regulations: 30 Potentially Material Business Impacts

California Attorney General Xavier Becerra has released updated regulations to the California Consumer Privacy Act (CCPA) that contain a number of material modifications to the initial CCPA regulations released in October...more

The Draft CCPA Regulations: 21 Potentially Significant Business Impacts

Our Privacy & Data Security Team summarizes the portions of California’s proposed regulations for the California Consumer Privacy Act (CCPA) that are likely of material interest to companies across industries and highlights...more

German DPAs to Survey Transfers in 500 Companies – with English Translation of DPA Questionnaire

Late last week, 10 of Germany’s 17 Data Protection Authorities (DPAs) announced they are planning to send written questionnaires to approximately 500 different companies regarding international data transfers. The following...more

German DPA Publishes First Privacy Shield Guidelines, Requires German-Law Contracts for Transfers

On June 7, 2016, the European Commission adopted the US-EU Privacy Shield. Companies that self-certify under Privacy Shield with the US Department of Commerce – dubbed “Privacy Shield organizations” – are thus officially...more

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