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New Requirements on the Collection and Use of Biometrics in Colorado Become Effective Soon

Last May, Colorado Governor Jared Polis signed into law amendments to the Colorado Privacy Act ("CPA") that impose new obligations governing the collection, processing, retention, and disclosure of Coloradans' biometrics. The...more

UPDATE: Net Neutrality Open Internet Order Set Aside

On May 7, 2024, the Federal Communications Commission (FCC) issued its latest network neutrality order, Safeguarding and Securing the Open Internet (the "Order"), which was published in the Federal Register on May 22, 2024,...more

Here We Go Again — FCC Proposes to Revive Net Neutrality Rules

On Monday this week, Anna Gomez was formally sworn in as the FCC's fifth commissioner, bringing the Commission back to its full complement and giving Chairwoman Rosenworcel a third Democratic vote. The very next day,...more

Oregon Consumer Privacy Act Signed Into Law

Oregon becomes the 12th state with a comprehensive consumer data privacy law - The Oregon Consumer Privacy Act (OCPA) became law on July 18, 2023. Oregon is the twelfth state to enact a comprehensive consumer data privacy...more

Texas Data Privacy and Security Act – An Overview

The Texas Data Privacy and Security Act (TDPSA) became law on June 16, 2023. Texas becomes the 11th state to enact a comprehensive consumer data privacy law, joining California, Virginia, Colorado, Connecticut, Utah, Iowa,...more

Connecticut Expands Regulation of Consumer Data Privacy

The Connecticut legislature passed and the governor recently signed amendments to the Connecticut Data Privacy Act (CTDPA), the state's comprehensive consumer data privacy law, which goes into effect July 1, 2023. Some...more

Montana Consumer Data Privacy Act Signed Into Law

Montana is the ninth state to enact a comprehensive consumer data privacy law - Montana Governor Greg Gianforte signed the Montana Consumer Data Privacy Act (MTCDPA) on May 19, 2023, after unanimous passage through the...more

New Washington Law Has Broad Implications For Protecting Consumer Health Data - Landmark ‘My Health My Data’ Act Reaches Beyond...

On April 27, 2023, Washington Governor Jay Inslee signed into law the My Health My Data Act (the "Act"), which will regulate the collection, use, and disclosure of "consumer health data" ("Consumer Health Data" or "CHD"). The...more

Generative AI, ChatGPT Undergoing Heightened Regulatory Scrutiny

Regulators, both in the United States and around the globe, are showing greater concern about the potential risks of using generative artificial intelligence (AI) systems for commercial and business purposes. The Federal...more

CPPA Solicits Comments on Cyber Audits, Risk Assessment and AI Tech

The California Privacy Protection Agency ("CPPA" or "Agency") is seeking preliminary comments on proposed rulemaking for risk assessments and cybersecurity audits for higher-risk data processing activities, and consumer...more

Recent Decisions Interpreting Illinois Biometrics Law Could Create "Ruinous Liability"

One can scarcely browse the internet without encountering a story on the use of Artificial Intelligence (AI) by businesses or websites. While recently most attention has focused on generative AI and the increasing use of chat...more

A First Look at the Colorado Privacy Act Proposed Rules

The Colorado Attorney General's Office has published its much-anticipated proposed rules (Proposed Rules) implementing the Colorado Privacy Act (CPA), which, as we discussed in an earlier blog post, was enacted on July 7,...more

CA Attorney General Settles With Online Retailer That Failed to Disclose "Sales" of Personal Information and Honor Global Privacy...

The Office of the California Attorney General (OAG) announced on August 24, 2022, a settlement with Sephora, Inc., as part of a recent enforcement sweep of online retailers. OAG alleged Sephora violated the California...more

FTC Proposed "Commercial Surveillance and Data Security" Rulemaking Raises Significant Questions About Risks Arising From...

The Federal Trade Commission has formally launched a rulemaking proceeding that nominally is focused on consumer privacy issues, but actually raises significant questions about the impact of artificial intelligence/machine...more

FTC Issues Advance Notice of Proposed Rulemaking on Commercial Surveillance and Data Security

The Federal Trade Commission (FTC) may have just taken its first steps towards the creation of generally applicable federal privacy and security rules. On Aug. 11, 2022, the FTC published an advance notice of proposed...more

Privacy in a Post-Roe World: What Businesses of All Types Should Consider

Following the U.S. Supreme Court's decision in Dobbs v. Jackson Women's Health Organization overruling Roe v. Wade, businesses and organizations that process personal data—including those outside the health or reproductive...more

And Utah Makes 4—Beehive State Passes Consumer Privacy Law (UPDATED)

Update March 31, 2022: Utah Governor Spencer Cox signed the bill into law March 24, 2022. With passage of the Utah Consumer Privacy Act (UCPA), Utah will become the fourth state to adopt omnibus consumer privacy...more

California Attorney General Issues Opinion Interpreting "Inferences" Under CCPA

The California Office of Attorney General (OAG) on March 10, 2022, issued its first opinion interpreting the California Consumer Privacy Act (CCPA), addressing when businesses must disclose internally generated "inferences"...more

And Utah Makes 4—Beehive State Passes Consumer Privacy Law

With passage of the Utah Consumer Privacy Act (UCPA), Utah will become the fourth state to adopt omnibus consumer privacy legislation—following California, Virginia, and Colorado— when Utah Governor Spencer Cox signs the...more

Illinois "Protecting Household Privacy Act" Takes Effect

Leading on the data privacy front again after passing one of the toughest biometric data privacy laws in the nation, Illinois is now the first state to expressly limit law enforcement access to household digital device data....more

Colorado Adds to the Privacy Law Patchwork – What to Expect

On July 7, Colorado became the third state to enact comprehensive data privacy legislation, following California and Virginia. The Colorado Privacy Act (CPA), modeled largely after its predecessor in Virginia (the Consumer...more

Challenges to Google's Collection of Web Browsing Data Survive Motion to Dismiss

A class action lawsuit will proceed against Google over its collection of data from users browsing in "incognito mode," as District Judge Lucy Koh denied Google's motion to dismiss on March 12, 2021. In Brown v. Google, Judge...more

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