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EU Fines EU?!: Alleged Unlawful Data-Transfer Dust-Up

Following a German case brought against the EU Commission, the EU General Court found that the Commission had made an improper transfer of personal information to the US. The plaintiff, a German citizen, alleged (among other...more

Don’t Forget the EU: Italy Issued First GenAI Fine of €15 Million Alleging GDPR Violations 

At the end of 2024 the Italian Data Protection Authority issued a 15 million euro fine in the first generative AI-related case brought under GDPR. According to Garante (the Italian authority), OpenAI trained ChatGPT with...more

Sheppard Mullin’s 2024 Eye on Privacy Year in Review

It is hard to believe that another year is upon us! As we have done in years past (including 2023, 2022, 2021, 2020, 2019 and 2018), we have created a comprehensive resource of all our www.eyeonprivacy.com posts from 2024. As...more

Colorado Rolls Out Updated Privacy Rules Ahead of 2025 CPA Amendments

The Colorado AG’s office adopted draft amendments to the Colorado Privacy Act rules last month. The adopted draft reflected input from the public to AG’s September 2024 version and addresses three key issues. First, on...more

New Year, New Protections for New York Artists and AI-Generated Replicas

New York has a new AI-related law which took effect January 1. The law regulates creation and use of digital replicas of an individual’s voice or likeness and is similar to those in California and Tennessee....more

New York Modifies Data Breach Law Heading Into 2025

As 2024 came to a close, New York Gov. Hochul signed two bills (A8872A and S2376B) amending New York’s data breach law. The modifications change both what constitutes personal information under the law, as well as modifying...more

FCC’s One-To-One Consent Rule Takes Effect in January

For those who send marketing texts, keep in mind the FCC one-to-one consent rule update. It has been getting some publicity, and takes effect January 27, 2025. As most are aware, TCPA requires getting consent before sending...more

FTC Keeps Sights on Data Brokers that Sell Sensitive Location Sites

The Federal Trade Commission recently settled complaints against two data brokers over their handling of consumers’ sensitive location information. The agency alleged that such practices constitute unfair practices. Under the...more

Coming to a State Near You: 5 State Privacy Laws Take Effect in January 2025

Are you ready for the next set of US state privacy laws going into effect? Delaware, Iowa, Nebraska, and New Hampshire are effective January 1, and New Jersey’s law go into effect two weeks later (January 15)....more

‘All Hands on Deck’ – White House Continues to Call on Agencies for AI National Security Plan

In the waning months of the current administration, the White House issued a memo setting forth actions focused on national security as directed in the AI Executive Order from last year. As a reminder, the order -while...more

California’s Privacy Regulator Had a Busy November, Data Broker Edition: What Does It Mean for Businesses?

In the fifth in our series of California developments, we turn to data broker obligations. There are two of note. First, the California privacy agency is moving forward Delete Act regulations it proposed earlier this year....more

California’s Privacy Regulator Had a Busy November, Cybersecurity Audits and Insurance Edition: What Does It Mean for Businesses?

In the fourth in our series of new CCPA regulations from California, we look at both cybersecurity audit obligations as well as the impact of the CCPA on the insurance industry. Cybersecurity Audits The proposed rules address...more

California’s Privacy Regulator Had a Busy November, Risk Assessment Edition: What Does It Mean for Businesses?

In the third in our series of new CCPA regulations from California, we look at obligations for conducting risk assessments under CCPA. CCPA had called on the California agency to promulgate rules to address such assessments,...more

California’s Privacy Regulator Had a Busy November, Automated Decisionmaking Edition: What Does It Mean for Businesses?

In the second in our series of new CCPA regulations from California, we look at proposed rules for use of automated decisionmaking technology. As a reminder, CCPA discusses these technologies in relation to profiling, namely...more

California’s Privacy Regulator Had a Busy November: What Does It Mean for Businesses?

The California Privacy Protection Agency released proposed CCPA rules for a variety of topics in November, as well as announcing an investigative sweep for compliance with the Delete Act. Topics include the following, which...more

Click! FTC Updates Its Negative Option Rule

The FTC updated its Negative Option Rule last month and gave it a new name to emphasize the expanded scope of programs to which it applies. It will now be the “Rule Concerning Recurring Subscriptions and Other Negative Option...more

New York AG Settles EnforcemENT Action with ENT

The New York Attorney General’s Office recently settled with Albany ENT & Allergy Services over claims that the healthcare provider failed to protect over 200,000 consumers’ private health information. The claims stem from...more

UK and US Issue Joint Statement on Children’s Privacy

The United Kingdom and the United States released a joint statement last month outlining plans focused on children’s online privacy. As indicated in the statement, they intend to engage national institutions and other...more

How Legitimate Is Your Business Interest? The EDPB Has Some Thoughts

The European Data Protection Board issued draft guidelines last month that outline when processing can be considered done for “legitimate interest.” The public has until November 20 to provide comments to the draft....more

#StatusUpdate on Social Media, Apps, and Children’s Privacy

Regulations impacting children’s use of social media continues to be a space in motion the past few months. There have been developments at both the state level, as well as with the FTC. And there is no sign of slowing down....more

EDPB Provides Insight for Use of Tracking Tools

The EDPB released guidance last month to help companies understand their obligations when using newer tracking tools. These include pixels, URL tracking, IP-tracking, and the like. First, some background: an EU law that...more

The Privacy and Data Security Impact of California’s Recent AI Bills

The dust is beginning to settle from the raft of AI-related bills Governor Newsom signed last month in California. (See for example, our post about neural data.) Most of the provisions will not go into effect for another few...more

Amendments to NYDFS’ Cybersecurity Regulations Take Effect November 1

The New York Department of Financial Services has modified its cybersecurity requirements for regulated entities. These requirements are in addition to those included in the regulations as last updated in November of last...more

FTC Social Media Staff Report Suggests Enforcement Direction and Expectations

The FTC’s staff report summarizes how it views the operations of social media and video streaming companies. Of particular interest is the insight it gives into potential enforcement focus in the coming months, and into 2025....more

California Joins Colorado in the Brain Wave Action

California’s governor has signed an amendment to CCPA, the state’s well-known privacy law. While California was the first to pass a “comprehensive” privacy law, it is the second -with this new amendment- to include “neural...more

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