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Schrems II Fallout Continued: Can Companies Rely on Consent?

The EDPB has provided input about consent in its recent FAQs responding to the Schrems II invalidation of Privacy Shield. As we wrote about previously in this series, Schrems II impacted how companies transfer data from the...more

CJEU Invalidates Privacy Shield, But Upholds SCCs with Conditions

On July 16, 2020, in the case colloquially known as “Schrems II,” the Court of Justice of the European Union (CJEU) struck down the EU-US Privacy Shield, finding it an invalid mechanism for transferring data from the EU to...more

Final Draft CCPA Regulations Submitted, Effective Date Unclear

On June 1, 2020, the California AG submitted the final text of the proposed CCPA regulations to the Office of Administrative Law (OAL). There were no changes to the final text from the last version released in March, which we...more

Can you Zigzag? California AG Releases Latest Draft of CCPA Regulations

On March 11, 2020, the second set of modifications (or the third version) of the CCPA draft regulations were released. While the number of substantive changes dwindled in this version, there are a number of drafting...more

The Privacy Shield Survives Another EU Commission Review, For Now…

The EU Commission concluded its third annual review of the EU-U.S. Privacy Shield and found that it continues to provide an adequate level of protection for EU personal data. The program was created as a mechanism to...more

Modifications Under CCPA To Receipt of Consumer Requests

One of the CCPA amendments that has gone to the governor’s desk is AB 1564, which addresses the methods companies must make available to consumers to exercise their rights under CCPA. Businesses which operate exclusively...more

CNIL Issues Record-Keeping Guidance

Under GDPR, companies are required to keep certain records of their processing activities. There has been some question about the types of records controllers should keep. To help clarify the questions arising from many...more

Privacy Developments in China, Singapore and Hong Kong

International companies should keep in mind recent developments coming out of Asia on the privacy front. Chinese authorities are reported to be confiscating smartphones at the border to install surveillance apps. Companies...more

Like a Butterfly, Will the CCPA Continue to Evolve?

California legislators have passed many bills to amend the California Consumer Protection Act since the law was passed. Last week there was significant developments in the status of those bills, as we reported. In addition to...more

North Dakota Data Misuse Law Amended

North Dakota criminal law currently contains penalties for misusing the personal information of another. That law has been expanded, and beginning August 1, 2019, it is a class B felony to use a skimmer or scanning device to...more

EDPB Seeks Comment On Online Services Guidance

The European Data Protection Board is seeking comment about proposed guidelines that impact websites that provide online services. This might include services a user pays for, or where the fee is indirect (the services being...more

NY AG Settles Over Mobile App Security Issues

Five companies settled with the New York Attorney General over mobile app data security issues at the end of last year. The AG alleged that the companies, Western Union, Priceline, Equifax, Spark Networks, and Credit Sesame,...more

CBPR System Grows with Entry of Australia and Chinese Taipei

2018 saw two new members of APEC’s Cross Border Privacy Rules (CBPR) system: Australia and Chinese Taipei. They join the US, Mexico, Canada, Japan, South Korea and Singapore...more

A Look Back at 2018 Privacy Shield Enforcement

Over the course of 2018, the FTC brought several actions against US companies for violations of the Privacy Shield program. The program, which as we have reported on previously gives participating US companies a mechanism to...more

US Breach Laws Are Coming: Vermont

On January 1, 2019 Vermont’s breach notice law will include obligations specific to data brokers. A “data broker” is defined as a business that “knowingly collects and sells or licenses to third parties the brokered personal...more

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