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Eye on Privacy: 2023 Year in Review

ARTIFICIAL INTELLIGENCE - What is the Privacy Impact of the White House AI Order for Businesses? Posted November 28, 2023 Biden’s sweeping AI Executive Order sought to have artificial intelligence used in accordance...more

EyeMed Data Breach Multistate Settlement

EyeMed recently entered into a settlement with the Attorneys General of Oregon, New Jersey, Florida and Pennsylvania around a 2020 breach of an EyeMed email account that contained the data of more than 2 million individuals....more

NYDFS’s $4.5 Million EyeMed Cyber Settlement Reminder To Industry

In a recent settlement with the New York Department of Financial Services, EyeMed Vision Care LLC agreed to pay a $4.5 million penalty and undertake remedial measures to increase its cybersecurity. This includes undertaking...more

Implications of SEC’s Scrutiny of Data Use Representations

The SEC’s enforcement action with a leading seller of market data (App Annie Inc.) signals its concern with misleading data use representations. While the data at issue was not “personally identifiable” information, but...more

What Does the Fifth Circuit’s Vacating of HHS HIPAA Fines Mean for Companies This Year?

Will HHS’ approach for imposing penalties in the aftermath of a data breach become a little clearer in 2021? This is a distinct possibility in the wake of a Fifth Circuit decision vacating penalties against MD Anderson Cancer...more

FTC Settles Over Alleged Failure to Manage Service Providers

The FTC recently settled with Ascension Data & Analytics for failure to oversee service providers. Ascension provides services to mortgage companies within its corporate family of entities. According to the complaint,...more

Illinois Joins States Requiring Breach Notice to AG

Illinois has updated its breach notice law to require, effective January 1, 2020, notice to the Illinois Attorney General of a data breach involving more than 500 Illinois residents. The law contains specific requirements...more

New York SHIELD Act Expands Breach Notice Requirements Starting in October

As we recently reported, New York’s new SHIELD Act contains data security provisions. It also contains a number of key changes to New York’s existing breach notification obligations. These changes will become effective...more

Preparing for New York’s New Data Security Requirements

New York recently passed the SHIELD Act, which, among other things, newly establishes data security requirements for companies that collect private information about New York residents. The data security protections required...more

Maryland Adds Requirements to Breach Notice Law

Maryland has amended its breach notification law to require businesses that maintain data, not just those that own or license the data, to conduct “a reasonable and prompt investigation” into whether personal information has...more

Texas Breach Law Will Change in 2020, To Require Attorney General Notification

New requirements to the Texas data breach statute, including a requirement to notify the Texas attorney general of a breach, are set to go into effect January 1, 2020. The legislation, signed by Texas Governor, Greg Abbot, on...more

New Jersey Breach Notice Law Expands To Cover Online Account Breaches

New Jersey joins a growing list of states that include user name, email address or any other identifier in combination with any password or security question and answer would permit access to an online account as personal...more

Happy First Day of Spring! Ohio Insurance Law Effective Today

Ohio recently followed South Carolina as the second state to adopt cybersecurity legislation modeled after the NAIC’s Insurance Data Security Model Law. The Ohio law, Senate Bill 273, applies to insurers authorized to do...more

Court Finds Cybersecurity-Related Claims Sufficient in Securities Class Action

In the aftermath of Equifax’s data breach, a federal court recently found that allegations of poor cybersecurity coupled with misleading statements supported a proper cause of action. In its decision, the U.S. District Court...more

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