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CPRA Shuffle: Two Steps Forward, One Step Back: Court Temporarily Halts CPRA Regulation Enforcement as CPRA Enforcements Begins

CPRA Regulations Delayed. On June 29, 2023, two days before enforcement of the California Consumer Privacy Act (CCPA) was to begin, a Sacramento Superior Court issued a temporary injunction, enjoining enforcement of newly...more

More Privacy, Please – July 2023

Editor’s Note: Texas, Oregon, and Delaware became the latest states to pass a comprehensive privacy bill, while the CPRA, Connecticut, and Colorado’s privacy laws came into force. In the litigation world, the FTC filed an...more

Storm Clouds Form Offshore Under Updated Florida Electronic Health Records Exchange Act

Background - On July 1, an amendment to the Florida Electronic Health Records Exchange Act (the Act) will go into effect. The Act focuses on information safety and sets forth stringent requirements that prohibit health...more

More Privacy, Please – June 2023

Editor’s Note: Montana became the latest state to pass a comprehensive privacy bill, joining California, Virginia, Colorado, Connecticut, Utah, and Tennessee. Florida, too, passed a privacy bill, but with a much narrower...more

More Privacy, Please - May 2023

Editor’s Note: Indiana became the latest state to enact a comprehensive privacy law, with Montana and Tennessee close behind. Washington passed sweeping legislation — the My Health My Data Act — which included a private right...more

Cookies and Online Tracking of Health Signals: An OCR Prescription for Potential Peril

Online Tracking Technologies and HIPAA. In December 2022, the Department of Health and Human Services Office for Civil Rights (OCR) published a bulletin on the use of online tracking technologies (e.g., cookies or web...more

Washington Legislature Goes Big With "My Health My Data Act"

On April 27, the state of Washington enacted the My Health My Data Act (MHMDA), a comprehensive health privacy law that imposes broad restrictions on how “consumer health data” can be used by companies doing business in the...more

Preparing for an Era of Regulated Artificial Intelligence

In recent months, there has been an explosion of artificial intelligence tools that have given even technophobes an opportunity to test AI’s power from the comfort of their favorite web browser. Originally published in...more

More Privacy, Please - April 2023

Editor’s Note: Iowa became the sixth state in the nation to enact a comprehensive privacy law, and California’s latest privacy regulations came into effect. At the federal level, Congress experienced a leak of sensitive...more

AI: Technology, Opportunities, Risks, and Best Practices (Part Two) – Regulatory Oversight Podcast [Audio]

Artificial intelligence (AI) has captured the imagination and generated excitement with consumers and businesses, but at the same time, developments in AI have also raised public concerns and spawned regulation that sometimes...more

Iowa on Cusp of Enacting Privacy Legislation

Recently, the Iowa Legislature sent a bill to Iowa Governor Kim Reynolds for her signature that would make Iowa the sixth state to enact a comprehensive privacy law. The Iowa Senate unanimously passed Senate File 262 (SF 262)...more

More Privacy, Please - March 2023

Editor’s Note: The U.S. Marshals Service suffered a data breach, demonstrating that no one is immune from such an occurrence. In regulatory news, government agencies remained focused on privacy, as the SEC proposed amendments...more

Silver Lining for Cos. in Proposed Calif. Privacy Law Changes

On Oct. 17 and again on Nov. 3, the California Privacy Protection Agency, or CPPA, modified the text of the proposed regulations implementing the California Privacy Rights Act, or CPRA. Originally published in Law360 on...more

Ad Technology Compliance Tips From Video Privacy Claims

“Stranger Things” has made many of us think back on the days when we waited at Blockbuster to pick the latest release of our favorite movies, sometimes at the return dropbox. And the use of the term “Borked” has probably not...more

More Privacy, Please - December 2022

Editor’s Note: In regulatory news, the Federal Trade Commission extended the deadline to comply with the Safeguards Rule, and Health and Human Services issued guidance for the use of online tracking technology under HIPAA. In...more

More Privacy, Please - November 2022

Editor’s Note: The California Privacy Protection Agency released amendments to its draft regulations, and the Consumer Finance Protection Bureau contemplates rulemaking on sharing financial data. In U.S. litigation, the first...more

More Privacy, Please - October 2022

Editor’s Note: In the U.S. laws and regulation space, the White House is focusing on privacy, evident through its session on accountability for big tech and the recent executive order highlighting cybersecurity risks....more

California Age-Appropriate Design Code Is Not Child’s Play - Five Practical Tips to Comply and Protect Kids’ Privacy

On September 15, 2022, California Governor Gavin Newsom signed Assembly Bill 2273 — the California Age-Appropriate Design Code Act (ADCA) — into law. Inspired by the United Kingdom’s (U.K.) Age-Appropriate Design Code, the...more

Deadline for New UK Contract Requirements for Personal Data Transfers Is Here (EU and California Deadlines Looming)!

Don't Hyperventilate. There are new United Kingdom (UK), European Union (EU), U.S., and global regulatory requirements that just went into effect or will be effective before or soon after year-end that will impact contracts...more

CCPA/CPRA Will Apply to Employee AND B2B Data — Five Steps to Prepare for the January 1, 2023 Effective Date

Exemption Extensions Failed. On August 31, California's legislature ended its 2022 session without adopting legislation to extend the California Consumer Privacy Act (CCPA) employee and business-to-business (B2B) personal...more

Not So Pretty: Top Takeaways From First CCPA Settlement With Sephora and Updated Enforcement Case Examples

With the notice and cure set to expire on January 1, 2023, California Attorney General Rob Bonta (CA AG) provided a glimpse at what to expect with its first settlement of alleged violations of the California Consumer Privacy...more

New York Department of Financial Services Proposes Amendments to Its Cybersecurity Regulation

On July 29, New York State’s Department of Financial Services (NYDFS) released draft amendments (Draft Amendments) to its Part 500 Cybersecurity Regulation for financial service companies that, among others things: (1)...more

CFPB Turns Its Attention to Data Security

On August 11, the Consumer Financial Protection Bureau (CFPB) published a circular, answering the question “Can entities violate the prohibition on unfair acts or practices in the Consumer Financial Protection Act (CFPA) when...more

More Privacy, Please - August 2022

Editor’s Note: In the U.S. laws and regulation space, federal lawmakers continued to push the American Data Privacy and Protection Act forward, and the FTC pledged to enforce the law against the illegal use of highly...more

Simplifying a Complicated Process — Four Steps to Comply with China’s PIPL New Security Assessment Requirements for Cross-Border...

Background on the PIPL Security Assessment. On July 7, China’s top regulator, the Cyberspace Administration of China (CAC), released the final version of the Measures for Security Assessment of Data Exports (Security...more

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