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Understanding Breach Notification Obligations Under California Law: What Does the CCPA Require? - Dear Mary – Incidents +...

‘Dear Mary,’ is Troutman Pepper’s Incidents + Investigations team’s advice column. Here, you will find Mary’s answers to questions about anything and everything cyber-related – data breaches, forensic investigations, how to...more

California AG Announces Second CCPA Settlement, Asserting DoorDash Failed to Deliver Privacy (UPDATE)

In a recent alert, we reported that California Attorney General (AG) Rob Bonta announced a settlement with DoorDash over allegations that the company violated the California Consumer Privacy Act (CCPA) and the California...more

California AG Announces Second CCPA Settlement, Asserting DoorDash Failed to Deliver Privacy

In the second settlement under the California Consumer Privacy Act (CCPA), California Attorney General (AG) Rob Bonta announced a settlement over allegations that DoorDash sold consumers' personal information in a manner that...more

More Privacy, Please – November/December 2023

In recent regulatory and enforcement developments, the California Privacy Protection Agency (CPPA) proposed a regulatory framework for automated decision-making technology (ADMT) and revisions to the California Consumer...more

More Privacy, Please - September/October 2023

Editor’s Note: The FTC continues to crack down on privacy and cybersecurity, including issuing a new warning to tax preparation companies and entering into a consent decree with 1Health.io. VPPA and BIPA litigation continues...more

More Privacy, Please - August/September 2023

Editor’s Note: As the summer months come to an end, there has been no shortage of privacy news and updates. Oregon signed both a comprehensive privacy law and data broker law, and the SEC adopted new rules regarding the...more

CPRA Shuffle: Two Steps Forward, One Step Back: Court Temporarily Halts CPRA Regulation Enforcement as CPRA Enforcements Begins

CPRA Regulations Delayed. On June 29, 2023, two days before enforcement of the California Consumer Privacy Act (CCPA) was to begin, a Sacramento Superior Court issued a temporary injunction, enjoining enforcement of newly...more

More Privacy, Please - September 2022

Editor’s Note: In the U.S. laws and regulation space, the California attorney general announced the first-ever CCPA settlement, the California Privacy Protection Agency raised objections to the ADPPA, and the FTC announced...more

CCPA/CPRA Will Apply to Employee AND B2B Data — Five Steps to Prepare for the January 1, 2023 Effective Date

Exemption Extensions Failed. On August 31, California's legislature ended its 2022 session without adopting legislation to extend the California Consumer Privacy Act (CCPA) employee and business-to-business (B2B) personal...more

Not So Pretty: Top Takeaways From First CCPA Settlement With Sephora and Updated Enforcement Case Examples

With the notice and cure set to expire on January 1, 2023, California Attorney General Rob Bonta (CA AG) provided a glimpse at what to expect with its first settlement of alleged violations of the California Consumer Privacy...more

California Privacy Protection Agency Publishes Draft Rules

The California Privacy Rights Act (CPRA) established the California Privacy Protection Agency (CPPA), and requires the CPPA to adopt, amend, and rescind regulations on 22 topics — including, among other things, definitions,...more

Troutman Pepper Weekly Consumer Financial Services COVID-19 Newsletter - May 2022 # 5

Like most industries today, Consumer Finance Services businesses continue to be significantly impacted by COVID-19. To help you keep abreast of relevant activities, below find a breakdown of some of the biggest legislative...more

CPRA Series: Part Four – Data Processing Obligation

The California Privacy Rights Action (CPRA) will significantly impact how entities process personal information requiring covered businesses to review and update their existing vendor agreements. The CPRA also includes...more

CPRA Series: Part Three – Notice and Disclosure Obligations

As we explained in an earlier installment, most privacy law derive from the Fair Information Practice Principles (FIPPs). The FIPPs provide, in part, that consumers should be given notice of how their information will be used...more

CPRA Series: Part Two – Consumer Rights

Most privacy laws derive from the same core foundational principles, namely the Fair Information Practice Principles (FIPPs). This includes the California Consumer Privacy Act of 2018 (CCPA), California Privacy Rights Act of...more

California Privacy Protection Agency Begins to Take Shape

The California Privacy Protection Agency (CPPA) is the first state privacy agency in the nation and was created as part of the California Privacy Rights Act (CPRA). While this agency has already been formed, it will not begin...more

JPML Articulates Limitations for Consolidation in Geico Data Breach Litigation

Despite overlap of alleged putative nationwide class definitions, the Judicial Panel on Multidistrict Litigation (JPML) denied Geico’s attempt to consolidate five class-action lawsuits arising from a data breach notification...more

Colorado Governor Signs Comprehensive Data Privacy Bill — How Does It Compare to California and Virginia?

On July 7, Governor Jared Polis signed Colorado's comprehensive data privacy bill (SB 21-190) into law. The Colorado Privacy Act (CPA) will go into effect on January 1, 2023, making Colorado the third state to enact a...more

More Privacy, Please - April 2021

Do you want a simple way to keep current on important privacy changes? Avoid sleepless nights wondering whether you missed a privacy speed bump or pothole between annual updates? Worry no longer. Troutman Pepper is pleased to...more

Litigation and Enforcement: Virginia Consumer Data Protection Act Series (Part Five)

Like the California Consumer Privacy Act of 2018 (CCPA) and the California Privacy Rights Act of 2020 (CPRA), the Virginia Consumer Data Protection Act (VCDPA) does not grant a private right of action for alleged violations...more

California Court Tosses Alleged "Data Breach" Suit, Holding CCPA Does Not Apply Retroactively

In Gardiner v. Walmart, Inc., a Walmart customer who purchased goods online filed a putative class action alleging that Walmart's cybersecurity procedures led to a purported unauthorized disclosure of his personal identifying...more

Notice and Disclosure Obligations: Virginia Consumer Data Protection Act Series (Part Three)

One key area where Virginia’s Consumer Data Protection Act (CDPA) differs from the California Consumer Privacy Act of 2018 (CCPA) and the California Privacy Rights Act of 2020 (CPRA) is the law’s notice and disclosure...more

California AG Announces Approval of Fourth Set of Modifications to CCPA Regulations

On March 15, California Attorney General Xavier Becerra announced that the California Office of Administrative Law approved his fourth set of proposed modifications to the California Consumer Privacy Act’s (CCPA) implementing...more

More Privacy, Please - February 2021

Do you want a simple way to keep current on important privacy changes? Avoid sleepless nights wondering whether you missed a privacy speed bump or pothole between annual updates? Worry no longer. Troutman Pepper is pleased to...more

No Federal Court Standing for Data Breach Claims Alleging Theft of Non-Sensitive Personal Information

A federal court in California has ruled that the plaintiff in a putative class action alleging theft of non-sensitive personal information arising from a cybersecurity data breach lacks Article III standing to maintain his...more

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