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NLRB General Counsel Memo on Electronic Monitoring of Employees

Responding in part to the nature of the post-COVID-19 remote workplace, NLRB GC Jennifer Abruzzo has released a memo on employers’ use of electronic monitoring and automated management in the workplace....more

OCR Reminds Healthcare Providers and Their Business Associates – You Need an Incident Response Plan!

We have been quite busy this October, which happens to be National Cybersecurity Awareness Month. But, we did not want to let the month go by without some recognition; and we are grateful to the HHS Office for Civil Rights...more

California Tightens Rules on Vehicle Tracking, Fleet Management

Over the past several years, there has been a significant increase in the use of dashcam technology. The technology available in the market is quite advanced. As we observed here, these devices can be equipped with...more

CPPA Board Publishes Proposed Modifications to CPRA Regulations in Advance of October Meeting

On October 21 and 22, the California Privacy Protection Agency (CPPA) Board will meet to discuss possible action regarding the proposed regulations for the California Consumer Privacy Act (CCPA) and California Privacy Rights...more

White House Weighs In On the Use of AI by Businesses

On October 3, 2022, the White House Office of Science and Technology Policy published its “Blueprint for an AI Bill of Rights.” This adds to prior federal guidance released by the EEOC and DOJ regarding the use of AI in...more

Amendment to CMIA Regarding Mental Health and Mental Health Apps

California passed Assembly Bill (AB) 2089, which amends the Confidentiality of Medical Information Act (CMIA) to include mental health application information under the definition of medical information....more

California Consumer Privacy Act FAQs: Employment Information

1. What’s changing? Under the current version of the California Consumer Privacy Act (“CCPA”), an employer’s obligations related to the personal information it collects from employees, applicants, and contractors residing...more

California Adopts Law That Seeks to Protect Children’s Online Privacy

California’s Governor signed Assembly Bill (AB) 2273, the first of its kind state legislation that requires businesses that provide online services, products, or features likely to be accessed by children to comply with...more

First California Consumer Privacy Act Enforcement Action and Settlement

August 24, 2022, marked a milestone for the California Consumer Privacy Act (CCPA), the California Attorney General announced the first enforcement and settlement against beauty retailer Sephora....more

Employers Get Ready – CCPA Employee and B2B Exemptions End, Expanded Privacy Compliance Begins in 2023

For the past few years, California’s comprehensive privacy law known as the California Consumer Privacy Act (“CCPA”) included an important partial exemption for employees, applicants, and independent contractors...more

New York State Bar Adds Cybersecurity, Privacy, and Data Protection as New CLE Category

On August 17, 2022, New York announced an amendment to the Continuing Legal Education (CLE) Program Rules, which adds a requirement for attorneys to complete at least one CLE credit hour in Cybersecurity, Privacy, and Data...more

Recent HIPAA Settlement Offers Lessons on Data Disposal and the Meaning of PHI

A $300,640 settlement announced yesterday by the Office for Civil Rights (OCR) provides important reminders about HIPAA Privacy Rule and data privacy practices generally: robust data disposal practices are critical and...more

Federal Trade Commission Considers Rulemaking Pertaining to Consumer Privacy & Data

On August 11, 2022, the Federal Trade Commission (FTC) announced proposed rulemaking pertaining to “commercial surveillance and lax data security.” However, the overall focus of the potential rulemaking is consumer privacy...more

Don’t Forget About Other Data Laws When It Comes to Connecticut Privacy Requirements

While the federal government attempts to move forward with a more uniform national law, Connecticut joined California, Colorado, Utah, and Virginia in passing a comprehensive consumer privacy law....more

Dobbs and Privacy: President Biden’s Executive Order and OCR HIPAA Guidance

In response to the United States Supreme Court decision in Dobbs vs. Jackson Women’s Health Organization, President Joe Biden signed an Executive Order on Friday, July 8, 2022, designed to protect access to reproductive...more

CPPA Releases Notice of Proposed Rulemaking

At the start of June, the California Privacy Protection Agency (CPPA), the agency tasked with implementing and enforcing the California Privacy Rights Act (CPRA) which amended the California Consumer Privacy Act (CCPA), voted...more

Congress Releases Draft Federal Privacy Law with Potential Traction To Pass

The federal government has been trying to reach a consensus on data privacy and thus far has failed to pass legislation. On June 3, 2022, a bipartisan draft bill, titled the American Data Privacy and Protection Act was...more

CPPA Votes to Proceed with CPRA Rulemaking

At the California Privacy Protection Agency (CPPA) Board meeting on June 8, 2022, the board voted to begin the rulemaking process. The Board previously released a 66-page draft of regulations, that are intended to implement...more

California Privacy Protection Agency Board Takes Steps Toward First Official Rulemaking

On June 8, 2022, the California Privacy Protection Agency (CPPA) Board, will meet to discuss and take potential action regarding a draft of its proposed regulations. The June 8th public meeting includes an agenda item where...more

North Carolina Prohibits Public Sector Entities from Paying Ransom in a Ransomware Cyberattack

Organizations attacked with ransomware have a bevy of decisions to make, very quickly! One of those decisions is whether to pay the ransom. Earlier this year, I had the honor of contributing to a two-part series, entitled...more

Indiana Tightens the State’s Deadline for Providing Notification of a Data Breach

States continue to tinker with their breach notification laws. The latest modification to the Indiana statute relates to the timing of notification. On March 18, 2022, Indiana Governor Eric Holcomb, signed HB 1351 which...more

FTC Blog: “The FTC Act creates a de facto breach disclosure requirement”

On May 20, 2022, the Federal Trade Commission’s Team CTO and the Division of Privacy and Identity Protection published a blog post entitled, “Security Beyond Prevention: The Importance of Effective Breach Disclosures.” ...more

EEOC, DOJ Release Expectations on Employers’ Use of Technology, AI for Employment Decisions

For decades, employers have used technology to help decision-making, from hiring to performance bonuses. While seemingly taking human biases out of the equation, the U.S. Equal Employment Opportunity Commission (EEOC) and the...more

Connecticut Likely to Become Fifth State to Enact Comprehensive Consumer Privacy Law

When the California Consumer Privacy Act of 2018 (CCPA) became law, it was only a matter of time before other states adopted their own statutes intending to enhance privacy rights and consumer protection for their residents. ...more

Draft Regulations in California Would Curb Use of AI, Automated Decision Systems in Employment

“The EEOC is keenly aware that [artificial intelligence and algorithmic decision-making] tools may mask and perpetuate bias or create new discriminatory barriers to jobs. We must work to ensure that these new technologies do...more

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