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SEC Adopts Rules on Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure

In Short - The Situation: On July 26, 2023, the U.S. Securities and Exchange Commission ("SEC") adopted final rules that significantly alter cybersecurity disclosure obligations for companies. The SEC's final rules adopt...more

Leading Technology Companies Agree to White House's AI Safeguards

On July 21, 2023, the White House announced that seven leading technology companies—Amazon, Anthropic, Google, Inflection, Meta, Microsoft, and OpenAI—voluntarily committed to mitigating the risks posed by artificial...more

European Union and United States Reach New Agreement for Data Flow Across the Atlantic

On July 10, 2023, the EU Commission adopted its adequacy decision for the EU-U.S. Data Privacy Framework, concluding that the United States ensures an adequate level of protection for personal data transferred from the...more

Commerce Department Issues Final Rule on Information and Communications Technology Supply Chain

On June 16, the U.S. Department of Commerce published a final rule, effective July 17, 2023, on Securing the Information and Communications Technology and Services ("ICTS") Supply Chain, signaling potential new actions on...more

FTC Proposes Updates to the Health Breach Notification Rule for Health Apps and Consumer Health Technologies

The Federal Trade Commission seeks to clarify how the Health Breach Notification Rule applies to health records collected by health apps and similar consumer health technologies. ...more

FTC Proposes to Impose Sweeping Restrictions on Tech Company's Ability to Profit From Youth Data

On May 3, 2023, the Federal Trade Commission ("FTC") issued an Order to Show Cause against Meta for alleged violations of Meta's 2012 and 2020 privacy orders and seeks to bar the company from monetizing data related to...more

My Health, My Data: Washington Enacts First State Comprehensive Health Privacy Law

The sweeping law imposes new requirements on the processing and sale of consumer health data in the state. On April 27, 2023, Washington State Governor Inslee signed the "My Health My Data Act" ("Act"). This Act marks the...more

New York City Releases Final Rules on Automated Employment Decision Tools

New York City regulators have finalized rules implementing the city's law requiring bias audits of automated employment decision tools, publication of audit results, notice to employees, and other requirements....more

Iowa Becomes Sixth State to Enact a Comprehensive Data Privacy Law

On March 28, 2023, Iowa—following California, Colorado, Connecticut, Utah, and Virginia—became the sixth state to adopt a comprehensive consumer data privacy law. On March 28, 2023, Iowa Governor Kim Reynolds signed "An...more

SEC Advances Three Cybersecurity Rule Proposals to Public Comment

If adopted, these proposed rules would (i) enhance protection of customer information under Regulation S-P, (ii) add new requirements addressing cybersecurity risk to the U.S. securities markets, and (iii) expand the types of...more

SEC Fines Company $3 Million for Allegedly Misleading Cyberattack Disclosures

Asserting that the company misstated the scope of data stolen in the cyberattack, the SEC provides a clear reminder that cybersecurity disclosures remain an agency priority....more

Vital Signs Digital Health Law Update | Winter 2023

Note From the Editors - We bring you Vital Signs, a curated, one-stop resource on the most notable digital health law updates from our U.S. and global contributors. In Industry Insights, our lawyers take an in-depth look at...more

Better Together: U.S. and EU Enter Artificial Intelligence Collaboration Agreement

The United States and European Union recently entered into an administrative agreement to collaborate on critical research related to artificial intelligence ("AI"), focusing on five key areas of significant global concern....more

Consumer Health Information and Increased Scrutiny: FTC Brings First Action Under Health Breach Notification Rule

The Federal Trade Commission ("FTC") has brought its first enforcement action for violations of the Health Breach Notification Rule ("HBNR"), signaling heightened federal agency scrutiny of digital health platforms,...more

U.S. National Institute of Standards and Technology Releases AI Risk Management Framework

The National Institute of Standards and Technology ("NIST") has released its AI Risk Management Framework ("AI RMF") as a resource to reportedly assist individuals, organizations, and society identify risks associated with...more

Australian Government Serious About Data Privacy: Substantial Increases in Fines and Enhanced Regulatory Powers

In Short - The Situation: Following a number of high-profile cyber incidents resulting in significant data breaches, the Australian Government has doubled down on its efforts to strengthen privacy laws and cybersecurity...more

Rising Global Regulation for Artificial Intelligence

Across multiple continents and industries, artificial intelligence ("AI") is a topic of intense focus by governments, research institutions, investors, and corporations—from start-ups to well-established industry players. As...more

California Privacy Protection Agency Modifies its Proposed Regulations

In Short - The Situation: The California Privacy Protection Agency ("CPPA" or "Agency") has modified its proposed regulations implementing many key California Privacy Rights Act ("CPRA") requirements....more

United States Signs Executive Order to Implement EU-U.S. Trans-Atlantic Data Privacy Framework

On October 7, 2022, President Biden signed an executive order on "Enhancing Safeguards for United States Signals Intelligence Activities," outlining the measures that the United States will take to implement its commitments...more

White House Announces Artificial Intelligence Bill of Rights

The Artificial Intelligence Bill of Rights sets forth voluntary guidelines that companies utilizing or developing technology with artificial intelligence can follow to protect users....more

European Commission Proposes New Liability Rules on Products and AI

On September 28, 2022, the European Commission published two proposals—the Revised Product Liability Directive and the AI Liability Directive—aimed at adapting liability rules to the green and digital transition within the...more

European Commission Proposes Legislation Imposing New Cybersecurity Requirements on Digital Products

On September 15, 2022, the European Commission ("EU") published a proposal for a Cyber Resilience Act, the first EU-wide legislation introducing a single set of cybersecurity rules for hardware and software products placed in...more

California Is First State to Adopt Age-Appropriate Design Code Law Alert

The California Age-Appropriate Design Code Act expands privacy requirements for businesses with online products, services, or features directed to or likely to be accessed by users under the age of 18....more

California Attorney General Signals CCPA Enforcement Priorities in $1.2 Million Sephora Settlement

On August 24, 2022, California Attorney General Rob Bonta announced his office's first privacy enforcement action and settlement against a publicly disclosed entity, Sephora, Inc., for violations of the CCPA, including the...more

Federal Privacy and Data Security Regulation on the Horizon: The FTC Announces Proposed Rulemaking

The Federal Trade Commission announced on August 11, 2022, that it is seeking public comment regarding its Advanced Notice of Proposed Rulemaking on commercial surveillance and data security. The Federal Trade Commission...more

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