NIST Publishes Report on the Cybersecurity of Genomic Data. On December 20, 2023, the NIST National Cybersecurity Center of Excellence (NCCoE) published Final NIST IR 8432, Cybersecurity of Genomic Data. Informed by direction...more
2/13/2024
/ Artificial Intelligence ,
Biometric Information ,
Biometric Information Privacy Act ,
Consumer Financial Products ,
Consumer Fraud ,
Cyber Attacks ,
Cybersecurity ,
Data Breach ,
Data Brokers ,
Data Privacy ,
Data Protection ,
Data Security ,
Federal Trade Commission (FTC) ,
Financial Services Industry ,
NIST ,
Personal Information ,
Personally Identifiable Information ,
Popular ,
Putative Class Actions
On January 16, New Jersey Governor Phil Murphy signed S332 (the act), making New Jersey the first state in 2024 to enact a comprehensive privacy law. Several other states are currently considering similar comprehensive...more
1/26/2024
/ Consumer Privacy Rights ,
Cybersecurity ,
Data Collection ,
Data Privacy ,
Data Protection ,
Data Security ,
Information Technology ,
New Jersey ,
Personal Data ,
Personally Identifiable Information ,
Regulatory Reform ,
State Data Privacy Laws
On November 1, New York Governor Kathy Hochul announced that the state’s Department of Financial Services (NY DFS) has amended its Cybersecurity Regulations to “enhance cyber governance, mitigate risks, and protect New York...more
11/6/2023
/ Chief Information Security Officer (CISO) ,
Cryptocurrency ,
Cybersecurity ,
Data Privacy ,
Data Protection ,
Financial Services Industry ,
New York ,
NYDFS ,
Regulatory Reform ,
Risk Assessment ,
State and Local Government
On October 19, the Consumer Financial Protection Bureau (CFPB) issued its highly anticipated notice of proposed rulemaking under Section 1033 of the Consumer Financial Protection Act of 2010 (CFPA). The proposed Personal...more
10/26/2023
/ Comment Period ,
Consumer Financial Products ,
Consumer Financial Protection Act (CFPA) ,
Consumer Financial Protection Bureau (CFPB) ,
Data Privacy ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Notice of Proposed Rulemaking (NOPR) ,
Open Banking ,
Personal Data ,
Proposed Rules ,
Regulation E ,
Regulation Z
The Consumer Financial Protection Bureau (CFPB) has started the process of issuing rules on several topics affecting the entire ecosystem that collects, sells, and uses data about consumers, according to an Outline of the...more
9/22/2023
/ Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Reporting Agencies ,
Data Brokers ,
Data Privacy ,
Fair Credit Reporting Act (FCRA) ,
Financial Services Industry ,
Proposed Rules ,
Regulatory Agenda ,
Rulemaking Process ,
SBREFA
Join us for the third episode in a special three-part series covering the CFPB's intention to propose new rules under the Fair Credit Reporting Act (FCRA). In this episode, Troutman Pepper Partners Chris Willis, Dave...more
Editor’s Note: As the summer months come to an end, there has been no shortage of privacy news and updates. Oregon signed both a comprehensive privacy law and data broker law, and the SEC adopted new rules regarding the...more
9/15/2023
/ Biometric Information ,
Biometric Information Privacy Act ,
California Consumer Privacy Act (CCPA) ,
Cybersecurity ,
Data Privacy ,
Data Protection ,
Data Security ,
Federal Trade Commission (FTC) ,
Fingerprints ,
Popular ,
Securities and Exchange Commission (SEC)
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
7/20/2023
/ California Privacy Rights Act (CPRA) ,
Data Breach ,
Data Privacy ,
Department of Health and Human Services (HHS) ,
Fair Credit Reporting Act (FCRA) ,
Federal Trade Commission (FTC) ,
Financial Services Industry ,
Health Insurance Portability and Accountability Act (HIPAA) ,
New Legislation ,
Personal Data ,
Popular ,
Securities and Exchange Commission (SEC) ,
Small Business ,
State Data Privacy Laws
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
6/21/2023
/ Biometric Information ,
Consumer Privacy Rights ,
Data Breach ,
Data Privacy ,
Data Protection ,
Data Security ,
Federal Trade Commission (FTC) ,
Financial Services Industry ,
New Legislation ,
Popular ,
Regulatory Reform ,
State Data Privacy Laws
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
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
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
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
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
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
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
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
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
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
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
9/1/2022
/ California Consumer Privacy Act (CCPA) ,
Consumer Privacy Rights ,
Corporate Counsel ,
Cybersecurity ,
Data Privacy ,
Data Protection ,
Data Security ,
Personal Information ,
Privacy Laws ,
Sephora ,
Statutory Violations
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
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
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
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
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