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Kentucky’s New Consumer Privacy Law: Is the Privacy Grass Greener in the Bluegrass State?

With the Kentucky governor recently signing into law that state’s privacy law the US now has 16 states with “comprehensive” privacy laws. This newest one will go into effect on January 1, 2026 – the same day as Indiana. It...more

New Hampshire, the Granite State, Joins Privacy Law Deluge: Sets Its Law in Stone

New Hampshire’s governor has signed into law the second state comprehensive privacy law of 2024. The law takes effect on January 1, 2025 – the same day as Iowa and Delaware (with New Jersey going into effect two weeks later)....more

ICO Has Concerns Over Facial Recognition Use

Earlier this month the UK privacy office put a stop to several related entities’ use of facial recognition technologies and fingerprint monitors for their employees. The UK Information Commissioner’s Office found that the...more

FTC Seeks Comments on AI Impersonation Rules

Earlier this month, accompanying an update to a rule prohibiting the impersonation of businesses and governments, the FTC sought comments on extending the rule to prohibit impersonation of individuals. The agency indicated...more

EDPB Provides Guidance on Determining Primary Supervisory Authority

This month the EDPB shed light on the question of lead supervisory authorities. The issue arose in response to a question late last month from the French supervisory authority. Some background. As most international...more

AI-Generated Voice Calls: New Tech, Old Rules

The FCC reminded companies this month that calls containing “artificial or prerecorded voices” are regulated by TCPA. And, that the FCC considers AI-generated voices to be just the kind of “artificial” that fall within the...more

DPA 101: Do You Know Where Your Data Is?

As more and more states enact laws that mirror aspects of GDPR, and as companies begin to get used to the EU’s new standard contractual clauses, now may be a good opportunity for a refresh on data sharing agreements. As most...more

UK ICO Uses AI In Cookie Banner Review

The UK Information Commissioner’s Office recently reported that it is continuing its review of website cookie banners. It had expressed concern late last year that these banners were not giving “fair choices” because they did...more

Eye on Privacy: 2023 Year in Review

ARTIFICIAL INTELLIGENCE - What is the Privacy Impact of the White House AI Order for Businesses? Posted November 28, 2023 Biden’s sweeping AI Executive Order sought to have artificial intelligence used in accordance...more

The Garden State Cultivates a Consumer Privacy Law – The First for 2024

New Jersey’s governor has signed into law the first US state comprehensive privacy law of 2024. It will go into effect January 16, 2025. For those keeping score, that puts New Jersey after Florida, Oregon, Texas (all July 1,...more

Privacy Day 2024: A Look Back at Developments from 2024

From the expansion of “general privacy” laws in US states and concerns over cross-border data transfers, to global focus on artificial intelligence, surveillance and dark patterns, 2023 was a busy year. Our privacy team...more

Current Status of US State Privacy Law Deluge: It’s 2024, Do You Know Where Your Privacy Program’s At?

As we begin the new year, many are wondering whether the growing list of US state privacy laws apply to them, and if so, what steps they should take to address them. For companies that gather information from consumers,...more

FTC Continues Focus on Data Brokers and Sensitive Information

The FTC is beginning 2024 with a bang. Just a few short days after announcing a settlement with lead-generation company Response Tree, the FTC has announced another decision. In this latest announcement, the FTC has described...more

Bookmark This!: Colorado Launches Universal Opt Out Mechanism List

In anticipation of July 1, 2024, requirements to allow consumers the ability to use “universal opt out mechanisms” in certain circumstances, Colorado has posted its “universal opt out shortlist.” The list is indeed short....more

FTC Reaches $7 Million Settlement Over Response Tree’s “Consent Farm” Sites

Continuing its focus on potential dark patterns, the FTC has reached a settlement with the lead generation company Response Tree LLC and its president over allegations that the company ran sites that tricked people into...more

Data Broker Rulemaking in Texas and Oregon

Both Texas and Oregon recently adopted rules that will, among other things, implement a registry required by both states’ data broker laws. The Texas law went into effect September 1, 2023, and the Oregon law will go into...more

California Releases Automated Decision Rules in Draft

The CPPA, the California regulatory body charged with enforcing CCPA, recently released draft regulations for use of automated decisionmaking technology. The draft comes under the law’s requirements for the agency to issue...more

Connected Devices: Eyes on EU Data Act

The European Council recently approved a final version of the EU Data Act. The Act applies to manufacturers of connected devices. Among other things, it gives consumers certain rights about the information those devices...more

FTC Decision with Global Tel*Link Signals Expectations for Use of Testing Environments

The FTC recently announced a settlement with Global Tel*Link, a telecommunications company that contracts with prisons and jails to provide communication services to incarcerated individuals and their families. Those who use...more

What Is the Privacy Impact of the White House AI Order for Businesses?

Biden’s sweeping AI Executive Order sought to have artificial intelligence used in accordance with eight underlying principles. The order, while directed to government agencies, will impact businesses as well. In particular,...more

CNIL Fines Canal+ Over Marketing and Data Security Concerns

The French Data Protection Authority announced a €600,000 fine against Groupe Canal+ over concerns with the media company’s direct marketing activities. According to the CNIL, the company sent users email marketing without...more

Amended Kochava Complaint Gives Insight into FTC’s View of Harm from Data Profiles

The FTC’s second attempt to pursue the data broker, Kochava, continues to move forward. The amended complaint, which was just unsealed and thus available for the public to review, gives insight into the agency’s perspective...more

FTC Vocalizes AI Voice Cloning Challenge

The FTC continues its focus and concern on use of technologies that integrate artificial intelligence, this time turning to potential consumer harm with voice cloning technology. Today the commission announced a challenge...more

Massachusetts Wagers Big on Privacy in Sports Betting

The Massachusetts Gaming Commission approved data privacy regulations under the 2022 Massachusetts Sports Wagering Act earlier this fall. While directed to a narrow group of companies, the restrictions around use of...more

No Need to Mind the Gap – UK Extension is a Data Bridge for US-UK Data Transfers

Beginning today, the UK adequacy decision for US data protection measures goes into effect. As a result, UK companies can transfer personal information to entities in the US that are participants in the EU-US Data Privacy...more

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