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OCR Enforcement Activity: Trends and Insights From a Limited Sample

Arecent report put the odds of an asteroid hitting the earth in December 2032 at 3.1%—which is 3,100 times more likely than an organization resolving an enforcement action with the U.S. Department of Health and Human...more

California Jumps Into Privacy Rulemaking (Again)

The California Privacy Protection Agency (CPPA) is starting formal rulemaking (again) as they move beyond the pre-rulemaking drafts that were debated for a little over a year. During their November 8, 2024, board meeting, the...more

Pennsylvania's Amended Data Breach Law Upends Standard Framework

Pennsylvania recently amended their data breach notification law in a way that turns the status quo on its head. The law, Senate Bill 824, adds an obligation to provide regulatory notice and tweaks the definition of personal...more

Privacy and Data Security Client Alert - July 2024

Pennsylvania's Amended Data Breach Law Upends Standard Framework - Pennsylvania recently amended their data breach notification law in a way that turns the status quo on its head. The law, Senate Bill 824, adds an...more

Bipartisan Group of Lawmakers Unveils Federal Privacy Bill

Over the weekend, a bipartisan and bicameral group in Congress unveiled a privacy proposal—The American Privacy Rights Act of 2024 (APRA)—along with a brief summary. The APRA builds on existing privacy frameworks at the state...more

Florida Legislature Passes Data Breach Immunity Legislation

The Florida legislature passed a bill that provides immunity to companies that suffer a data breach. The immunity is conditioned on the company: (1) complying with the notice requirements of Florida’s data breach notification...more

California Shares Draft Rules on Audits, Assessments, and Automated Decisionmaking

On November 27, California’s dedicated privacy law enforcement agency, the California Privacy Protection Agency (CPPA), released a draft of new rules covering automated decisionmaking (yes, they made “decisionmaking” one...more

OCR Faults Business's Data Security Practices After Ransomware Attack

The U.S. Department of Health and Human Services, Office for Civil Rights (OCR) recently announced its first settlement agreement related to a ransomware attack. But it was not the ransomware that triggered OCR’s enforcement...more

New York adds more stringent cybersecurity requirements

The New York Department of Financial Services (NYDFS) released the final amendments to its cybersecurity rules for financial, banking and insurance companies. The changes add obligations for accountability, incident...more

SEC Issues Rules on Cybersecurity Reporting Obligations

On July 26, the Securities and Exchange Commission (SEC) issued new rules adding cybersecurity disclosures for public companies in three areas: cybersecurity incidents, governance, and risk management and strategy. The new...more

California DOJ Treats Data Transfers for Website Analytics as a Sale in First CCPA Settlement

Do you use Google Analytics? Do you tell consumers that you do not sell personal information? If you answered yes to both of those questions, then this alert is for you! The California attorney general recently took the...more

Practical Suggestions for CCPA Compliance

Let’s face it: CCPA compliance is not easy. And a recent study provides additional evidence for the commonsense conjecture that companies trying to just “follow the law” often do more or less than is required. In this alert,...more

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