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Federal Regulators' Artificial Intelligence Initiative Is a Promising Development for Financial Industry (Update)

Update: On May 17, 2021, the agencies extended the deadline for comments from June 1, 2021, to July 1, 2021. The text of this post has been updated accordingly....more

Federal Regulators' Artificial Intelligence Initiative Is a Promising Development for Financial Industry

The federal financial institutions regulatory agencies collectively issued a Request for Information and Comment (RFI) on March 31, 2021, to better understand how artificial intelligence (AI) and machine learning (ML) are...more

Challenges to Google's Collection of Web Browsing Data Survive Motion to Dismiss

A class action lawsuit will proceed against Google over its collection of data from users browsing in "incognito mode," as District Judge Lucy Koh denied Google's motion to dismiss on March 12, 2021. In Brown v. Google, Judge...more

Virginia Poised to Enact Comprehensive Consumer Privacy Law

Virginia's legislature has set the stage for the Commonwealth to join California as one of two states with comprehensive consumer privacy legislation. The Virginia Consumer Data Protection Act (VCDPA) pulls certain policy...more

2020 State Consumer Privacy Law Round-Up

As the year draws to a close, it seems safe to declare that 2020 was not a good year for the enactment of state consumer privacy legislation. Below, we provide status updates on state privacy task force initiatives and...more

California Voters Pass Proposition 24 – the California Privacy Rights Act

As expected, Californians voted on November 3, 2020, to adopt the California Privacy Rights Act (CPRA), better known as Proposition 24. The CPRA amends the California Consumer Privacy Act (CCPA) in subtle and significant ways...more

CFPB Initiates Process to Regulate Financial Data Access

Last week, with the issuance of an Advance Notice of Proposed Rulemaking (ANPR), the Consumer Financial Protection Bureau (CFPB) announced its intention to explore regulation of open banking. The Notice requests public input...more

CCPA Regulations Receive Final Approval (With Changes): Effective Immediately

Regulations implementing the California Consumer Privacy Act (CCPA) became final last week, following approval by the California Office of Administrative Law (OAL). While four provisions from the final regulations were...more

Passport to Privacy: Lessons From EU Guidance on COVID-19 and Personal Data

Attempts by U.S. legislators to address the privacy issues raised by the ongoing COVID-19 pandemic have stalled. But for companies seeking to balance the goals of furthering public health and protecting individuals' privacy,...more

EU High Court Invalidates EU-U.S. Privacy Shield

The Court of Justice of the European Union (CJEU) issued a long awaited opinion yesterday (July 16, 2020) in Data Protection Commissioner v. Schrems1 finding the EU-U.S. Privacy Shield inadequate for lawfully transferring the...more

C Is for Cookie Lawsuit: Google Accused of Wiretap Act Violations for Collection of Web Browsing Data

A new class action against Google in federal court in San Jose, Calif., claims that Google's collection of web browsing data from individuals who have enabled "private browsing mode" violates the Federal Wiretap Act, 18...more

With Less Than One Month Until Enforcement Begins, CCPA Regulations Give Businesses a To-Do List

Less than one month remains until the July 1 date when California’s attorney general may begin enforcing the California Consumer Privacy Act (CCPA) which went into effect at the beginning of this year. ...more

Washington, D.C. Adds Security Requirements in New Data Breach Notification Law

Washington, D.C. amended its data breach notification law (D.C. Act 23-268) on March 26, 2020, expanding the definition of personal information covered by the law and requiring businesses collecting data from D.C. residents...more

In Tightening Your Belt, Don’t Loosen Your Privacy Controls

"Privacy, Unmasked" is a multi-part series that explores the impact of COVID-19 on individual privacy rights and privacy and security regulation and enforcement. New blogs will be posted in this space on Tuesdays....more

COVID-19 Highlights New Privacy Challenges for BigTech, Lawmakers

For companies known for using technology and analysis of big data to disrupt markets, the pandemic has created new opportunities, both to develop products that meet demands of a stay-at-home society and to share and analyze...more

Security and Privacy Urgent Care: COVID-19 Is a Threat to Your Health and Your Network

COVID-19 is first and foremost a threat to our health, but as many organizations are quickly discovering, it also raises novel questions about privacy and security. We recognize that privacy and security are two of many, many...more

State Consumer Privacy Law Round-Up - February 2020 #2

While all eyes are on the state of Washington's proposed privacy act for the final legislative week, consumer privacy rights continue to be a hot topic in a handful of other state legislatures. ...more

Privacy Law Issues to Watch in 2020

Go to the gym. Eat less sugar. No booze for January. Pass privacy legislation. As legislatures across the country opened for new sessions in January, it was evident that many representatives had added "expand individual...more

State Consumer Privacy Law Round-Up - February 2020

As the likelihood of the federal government passing a timely, workable national consumer privacy law before the November election decreases, states from coast to coast have been busy. According to the National Conference of...more

“Oh AG, Please Don’t Let Me Be Misunderstood”: Breaking Down Common CCPA Myths

"I’m just a law whose intentions are good / Oh AG, please don’t let me be misunderstood." - Nina Simone, Don’t Let Me Be Misunderstood, as adapted by the DWT Privacy & Security Team...more

Shooting at a Moving Target: The Continuing Saga of Possible CCPA Amendments

Six bills proposing various changes to the California Consumer Privacy Act (CCPA) continue to move through the state’s legislature, and are likely to come up for a final floor vote imminently. None of the proposed amendments...more

CCPA Compliance – Limited Time Offers, Act Now

With summer vacations, BBQs, and heat waves still in full swing, it can be tempting to think there is plenty of time remaining until the California Consumer Privacy Act ("CCPA") takes effect on January 1, 2020. ...more

The NIST Privacy Framework: Updates and Opportunities

While federal legislators still appear unable to reach consensus on the content of national privacy legislation, the National Institute of Standards and Technology (NIST) is moving forward with its plan to issue a “Privacy...more

Location, Location, Location: Recent Developments in Location Data Privacy

Privacy issues surrounding location data were in the news this month. Hawaii’s legislature passed a bill to regulate the sale of GPS data which now awaits the governor’s decision to sign it or veto it....more

State Consumer Privacy Law Round-Up

Copy-cat CCPA bills sprung up across the country in February, but as state legislatures move toward the lazy hazy days of summer, many of these bills seem to have lost momentum. ...more

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