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Delaware Enacts Comprehensive Data Privacy Law

On September 11, 2023, Delaware Governor John Carney signed into law House Bill No. 154 ("Delaware Personal Data Privacy Act"), Delaware's new state consumer privacy law, which will become effective January 1, 2025. Delaware...more

CPRA Enforcement Activity Underway Despite Court Ruling to Delay

The California Attorney General's (the "Cal AG") office appears to be moving forward with enforcement activities, despite a recent court ruling delaying enforcement of CPRA regulations. In the past month, since the amendments...more

US and EU Approve Framework for Personal Data Transfers

The United States ("U.S.") and the European Union ("EU") have settled on a framework for transfers of personal data for the first time since the European Court of Justice ("CJEU") effectively invalidate the EU-U.S. Privacy...more

Texas Passes Comprehensive Data Privacy Law

On June 18, 2023, Governor Greg Abbott signed the Texas Data Privacy and Security Act (TDPSA) into law. Texas now joins the rapidly increasing group of states, California, Utah, Colorado, Connecticut, Virginia, Iowa, Indiana,...more

Tennessee Passes Comprehensive Data Privacy Law

On May 11, 2023, Governor Bill Lee signed the Tennessee Information Protection Act (TIPA) into law. Tennessee now joins the rapidly increasing group of states, California, Utah, Colorado, Connecticut, Virginia, Iowa and...more

Montana Joins the Growing Number of States with a Comprehensive Data Privacy Law

On May 19, 2023, Montana Governor Greg Gianforte signed into law Senate Bill 384 ("Montana Consumer Data Privacy Act"), Montana's new state consumer privacy law, which will become effective October 1, 2024. Montana now joins...more

Key Response Steps for Businesses Impacted by Recent Global Cyberattack Exposing the Personal Information of Millions

As of this morning, several US federal agencies and the personal information of 3.5 million Oregon and Louisiana residents has been compromised in a cyberattack affecting companies and government agencies across the globe...more

Supreme Court Declines to Reconsider Foundational Principles of Internet Platform Liability

On May 18, 2023, in Twitter, Inc. v. Taamneh, the Supreme Court issued a unanimous opinion declining to impose secondary liability on tech companies for allegedly failing to prevent ISIS from using their platforms for...more

The CPPA Issues Statement of Reasons for the California Privacy Rights Act Regulations Providing Guidance on Implementing the CCPA

After a delay of eight months, the California Privacy Rights Act Regulations (CPRA) (the "Regulations") were finalized in late March of this year. The Regulations remain unchanged from the final modified version of the draft...more

Indiana Becomes the Seventh State to Enact a Comprehensive Data Privacy Law

On May 1, 2023, Indiana Governor Eric Holcomb signed into law Senate Enrolled Act No. 5 ("Indiana Data Privacy Law"), Indiana's new state consumer privacy law, which will become effective January 1, 2026. Indiana now joins...more

Iowa Enacts Data Privacy Legislation with Senate File 262

On March 28, 2023, Iowa Governor Kim Reynolds signed into law Senate File 262 ("Iowa Data Privacy Law"), Iowa's new state consumer privacy law, which will go into effect on January 1, 2025. By passing this law, Iowa joins...more

Colorado Privacy Act Rules Finalized Ahead of July 1, 2023 Effective Date

The Colorado Attorney General's Office recently finalized rules for the Colorado Privacy Act ("CPA Rules") which was signed into law in July 2021. The Colorado Privacy Act ("CPA") will soon join the California Consumer...more

Cybersecurity Developments and Legal Issues

For most large companies, a frictionless flow of information and the ability to transfer customer data, employee files, financial records and other information around the world quickly and cost-effectively is a critical...more

California Attorney General Warns of Enforcement Focus on Mobile App Compliance with CCPA

On January 27, 2023 California Attorney General Rob Bonta ("Cal AG") announced a new enforcement sweep, aimed at businesses with mobile apps that do not comply with the California Consumer Privacy Act ("CCPA"). The...more

Biden Executive Order Seeks to Solidify European Union-U.S. Data Privacy Framework

After a two year absence of a legal framework for transferring personal data from the EU to the U.S., President Biden signed an Executive Order on Enhancing Safeguards for United States Signals Intelligence Activities (the...more

Upcoming California Privacy Rights Act: Key Compliance Tasks for California Employers

California employers' reprieve from obligations to employees to disclose data privacy practices and provide access rights to employees appears to be coming to an end as the California Privacy Rights Act (CPRA) becomes...more

California Attorney General Bark Turns to Bite as First CCPA Settlement Includes Monetary Penalty

In a long anticipated development, on August 24 California Attorney General Rob Bonta ("Cal AG") announced the state's first monetary penalty under the California Consumer Privacy Act ("CCPA"), in a settlement with the beauty...more

New York State Department of Financial Services Imposes $30 Million Fine in First Cryptocurrency Enforcement Action

On August 2, in its first ever cryptocurrency enforcement action, the New York State Department of Financial Services ("NYDFS") announced it had imposed a $30 million fine on Robinhood Crypto, LLC ("RHC") for failures in its...more

Connecticut Lends Its Hand to U.S. Data Privacy Framework

This week, on Tuesday May 10, 2022, Connecticut Gov. Ned Lamont approved Connecticut Senate Bill 6, an Act Concerning Personal Data Privacy and Online Monitoring (the "Connecticut Privacy Act"). Governor Lamont’s approval...more

The Utah Consumer Privacy Act: Utah Becomes Fourth US State with Comprehensive Privacy Law

Continuing efforts at the state level to establish a data privacy framework in the US, a fourth state has passed a comprehensive consumer privacy law. Utah has joined the ranks of Colorado, California and Virginia after...more

SEC Proposes Mandatory Cybersecurity Disclosure Rules

On March 9, 2022, the Securities and Exchange Commission ("SEC") proposed rules that would require public companies to make prescribed cybersecurity disclosures. The proposed rules would "strengthen investors' ability to...more

Good security practices for data and networks are essential to M&A success

With data privacy laws tightening and cyberattacks on the rise, due diligence of technology networks and data processes should be a top priority for dealmakers - May 2021 saw one of the most high-profile cyberattacks in US...more

Taking Your First Steps: Key Compliance Tasks to Kick-start Compliance with California and Virginia Data Privacy Laws

As state and federal legislatures across the United States continue to contemplate comprehensive data protection legislation, two pending laws—the California Privacy Rights Act (CPRA) and the Virginia Consumer Data Protection...more

Time to Revisit Risk Factors in Periodic Reports

Ninth Circuit Decision Highlights Importance of Updating Risk Factors to Address Material Developments, including those relating to Cybersecurity Risks. As companies prepare their periodic reports with the SEC, a recent...more

Colorado Privacy Act: US Consumer Data Privacy Framework Continues Expansion

Colorado has joined California and Virginia in enacting comprehensive data privacy legislation after Governor Jared Polis signed the Colorado Privacy Act into effect yesterday. The enactment of the Colorado Privacy Act...more

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