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California’s Privacy Regulatory Odyssey Continues: Formal CCPA Rulemaking on the Horizon Amidst Expanded Data Broker Requirements

On November 8, 2024, the California Privacy Protection Agency (CPPA) Board met to discuss and vote on various proposed California Consumer Privacy Act (CCPA) regulations related to cybersecurity audits, automated...more

Governor Newsom Signs (and Vetoes) Major California AI Legislation

California’s 2024 legislative session has been marked with exciting developments and a clear focus on setting the rules of the road for artificial intelligence (AI), with some measures becoming law and others stalling out...more

Colorado Department of Law Proposes Amendments to the Colorado Privacy Act Regulations Regarding Biometric and Minors’ Data

On September 13, 2024, the Colorado Attorney General’s office (the Colorado Department of Law) proposed draft amendments (draft regulations) to its Colorado Privacy Act (CPA) regulations, which took effect in 2023. The draft...more

New Federal Data Broker Restrictions Signed into Law

The recent omnibus foreign relations package signed by President Biden on April 24, 2024, includes the Protecting Americans’ Data from Foreign Adversaries Act of 2024 (the Act), a set of sweeping privacy provisions...more

Congress Proposes New Comprehensive Privacy Legislation: The American Privacy Rights Act

On April 7, 2024, Representative Cathy McMorris Rogers (R-WA) and Senator Maria Cantwell (D-WA) announced that Congress will once again consider a comprehensive federal data privacy bill that, if passed, would dramatically...more

New Executive Order Restricts Certain Cross-Border Transactions Involving Sensitive Personal Data of U.S. Citizens

On February 28, 2024, President Biden signed Executive Order 14117 (the Order) aimed at protecting Americans’ sensitive personal data and U.S. Government-related data from exploitation by “countries of concern.” This move...more

California Appeals Court Moves Up Enforcement Date for Latest CCPA Regulations

On February 9, 2024, the California Third District Court of Appeals in Sacramento overturned a lower court order that postponed enforcement of the California Privacy Protection Agency’s (CPPA) newest rules. The decision...more

CFPB Announces Proposed Rules to Accelerate Open Banking

On October 19, 2023, the Consumer Financial Protection Bureau (CFPB) announced its long-awaited proposed rule regulating “Personal Financial Data Rights” (the proposed rule). The proposed rule implements Section 1033 of the...more

UK-U.S. Data Bridge Commencement Date Announced

On September 21, 2023, the UK Government announced the establishment of the “UK-US data bridge” (the Bridge), also known as the UK Extension to the EU-U.S. Data Privacy Framework (the DPF). The announcement promises to...more

EU and U.S. Finalize Data Privacy Framework: Here’s How to Get Certified

On July 10, 2023, the European Commission (EC) adopted an adequacy decision in relation to the EU-U.S. Data Privacy Framework (DPF). This paves the way for organizations to certify to the DPF, reducing friction for transfers...more

UK and U.S. Commit to Establish a "Data Bridge" to Facilitate the Free Flow of Personal Data

On June 8, 2023, the UK and the U.S. governments issued a joint statement announcing that they had committed in principle to the establishment of a “UK Extension to the Data Privacy Framework,” which would facilitate flows of...more

FTC Announces Proposed Settlement with Premom Fertility Tracking App for Privacy Practices

On May 17, 2023, the Federal Trade Commission (FTC) announced a proposed settlement agreement (in the form of a stipulated order) with Easy Healthcare Corporation, which operates the Premom fertility tracking app (Premom)....more

The Sixth State: Iowa Enacts Comprehensive Privacy Law

On March 28, 2023, Iowa Governor Kim Reynolds signed “An Act Relating to Consumer Data Protection” (SF 262) (ICDPA), making Iowa the sixth U.S. state to enact a comprehensive consumer privacy law following California,...more

Colorado AG’s Office Announces Final Colorado Privacy Act Rules: Key Takeaways

On March 15, 2023, the Colorado Attorney General’s (Colorado AG) office released the final version of the Colorado Privacy Act (ColoPA) rules (the final rules), which are based on public comments on the third version of the...more

EU Privacy Regulators Coordinate to Assess Compliance with the GDPR Rules on Data Protection Officers

On March 15, 2023, the European Data Protection Board (EDPB) announced a coordinated action on the role of the data protection officers (DPOs). The data protection authorities (DPAs) will ask DPOs a series of questions to...more

White House Releases National Cybersecurity Strategy: Key Takeaways for the Private Sector

On March 2, 2023, the White House released its National Cybersecurity Strategy (the Strategy). The Strategy sets out ambitious goals for the federal government to hold countries accountable for irresponsible behavior in...more

European Commission Seeks Companies' Input on GDPR Enforcement

On February 24, 2023, the European Commission (EC) opened a public consultation on its initiative (Initiative) to revise procedural rules relating to the enforcement of the EU General Data Protection Regulation (GDPR). The EC...more

FTC Announces First Enforcement Action Under the Health Breach Notification Rule Against GoodRx

On February 1, 2023, the Federal Trade Commission (FTC) announced a complaint against and proposed settlement agreement (the “proposed order”) with GoodRx, a digital health company, over its data sharing practices that...more

Privacy Legislation Update: The “Three Corners” Bill and the Cantwell Draft

On June 3, 2022, members of the U.S. Congress released a bipartisan, bicameral discussion draft of a comprehensive national data privacy and data security framework. The draft is notable in that it reflects a compromise on...more

Privacy and Security of Health Information: A Primer for Digital Health Companies

COVID-19 has rapidly accelerated our expectations that virtual connection can deliver better and more economical care. As a result, digital health companies have an unprecedented opportunity to innovate, but with that...more

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