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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

Department of Education Announces Required Cybersecurity Updates for Postsecondary Institutions to Comply with the Safeguards Rule

On February 9, the U.S. Department of Education (ED) released an announcement about updates that postsecondary institutions must make to their cybersecurity and data protection policies in order to comply with the Federal...more

More Privacy, Please - February 2023

Editor’s Note: As the nation celebrated National Privacy Day on January 28, in regulatory news, the Colorado AG published a third version of its proposed regulations, and the CPPA voted to submit its draft regulations to the...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

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

FTC Extends Deadline for Compliance With Safeguards Rule

The deadline for complying with certain provisions of the Standards for Safeguarding Customer Information (Safeguards Rule) has been extended to June 9, 2023. As we previously posted, on January 10, the Federal Trade...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

Privacy and Data Security Update - The Consumer Finance Podcast [Audio]

Please join Consumer Financial Services Partner Chris Willis and his colleagues Ron Raether and Kim Phan, partners in our Privacy + Cyber Practice Group, as they discuss recent privacy and data security updates in the...more

More Privacy, Please - September 2022

Editor’s Note: In the U.S. laws and regulation space, the California attorney general announced the first-ever CCPA settlement, the California Privacy Protection Agency raised objections to the ADPPA, and the FTC announced...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

Proposed New Data Security Rules Could Prove Duplicative, Forcing Banks to Turn Over Dangerous Amounts of Secured Data

An amendment to the National Defense Authorization Act passed by the House in July would create a “systemically important entity” designation, applying new regulations and offering priority aid to certain critical...more

More Privacy, Please - July 2022

Editor’s Note: In the U.S. laws and regulation space, federal lawmakers formally introduced bipartisan comprehensive federal privacy legislation titled, the American Data Privacy and Protection Act. Meanwhile, California...more

California Privacy Protection Agency Publishes Draft Rules

The California Privacy Rights Act (CPRA) established the California Privacy Protection Agency (CPPA), and requires the CPPA to adopt, amend, and rescind regulations on 22 topics — including, among other things, definitions,...more

CPRA Series: Part Three – Notice and Disclosure Obligations

As we explained in an earlier installment, most privacy law derive from the Fair Information Practice Principles (FIPPs). The FIPPs provide, in part, that consumers should be given notice of how their information will be used...more

Connecticut Legislature Passes Comprehensive Privacy Legislation, Awaiting Governor’s Signature

On April 28, the Connecticut House passed Senate Bill 6, an act concerning personal data privacy and online monitoring (SB 6 or Connecticut Act). The Senate unanimously passed SB 6 on April 20, and is now currently under...more

US and Europe Issue Joint Statement Announcing Agreement on New Trans-Atlantic Data Privacy Framework to Replace EU-US Privacy...

On March 25, a huge sigh of relief was heard from businesses and organizations located throughout the United States and Europe after the U.S. and European Commission announced their agreement in principle on a new...more

Utah Becomes Fourth State to Adopt Privacy Legislation

On March 24, Governor Spencer J. Cox signed the Utah Consumer Privacy Act (UCPA), making Utah the fourth state in the country to adopt a comprehensive privacy law. The UCPA is set to take effect on December 31, 2023, and this...more

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