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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 - April 2023

Editor’s Note: Iowa became the sixth state in the nation to enact a comprehensive privacy law, and California’s latest privacy regulations came into effect. At the federal level, Congress experienced a leak of sensitive...more

Iowa on Cusp of Enacting Privacy Legislation

Recently, the Iowa Legislature sent a bill to Iowa Governor Kim Reynolds for her signature that would make Iowa the sixth state to enact a comprehensive privacy law. The Iowa Senate unanimously passed Senate File 262 (SF 262)...more

More Privacy, Please - March 2023

Editor’s Note: The U.S. Marshals Service suffered a data breach, demonstrating that no one is immune from such an occurrence. In regulatory news, government agencies remained focused on privacy, as the SEC proposed amendments...more

More Privacy, Please - February 2023

Editor’s Note: As the nation celebrated National Privacy Day on January 28, in regulatory news, the Colorado AG published a third version of its proposed regulations, and the CPPA voted to submit its draft regulations to the...more

Ad Technology Compliance Tips From Video Privacy Claims

“Stranger Things” has made many of us think back on the days when we waited at Blockbuster to pick the latest release of our favorite movies, sometimes at the return dropbox. And the use of the term “Borked” has probably not...more

Four Strategies for Drafting Effective Consumer Breach Notices

It is 2022, which means you’ve received your fair share of consumer breach notification letters. Originally published in Law360 on September 30, 2022....more

More Privacy, Please - December 2022

Editor’s Note: In regulatory news, the Federal Trade Commission extended the deadline to comply with the Safeguards Rule, and Health and Human Services issued guidance for the use of online tracking technology under HIPAA. In...more

The Do's and Dont's of Cybersecurity Forensic Investigations

According to the Verizon Wireless 2022 Data Breach Investigations Report, there are four prominent paths that threat actors use to gain unauthorized access into an organization’s network... Originally published in Law360 on...more

More Privacy, Please - November 2022

Editor’s Note: The California Privacy Protection Agency released amendments to its draft regulations, and the Consumer Finance Protection Bureau contemplates rulemaking on sharing financial data. In U.S. litigation, the first...more

Drafting Consumer Breach Notices — From a Litigation Perspective - Unauthorized Access Podcast [Audio]

In this episode of Unauthorized Access, Kamran and Sadia welcome their firm colleague, Privacy + Cyber Partner and Team Leader Ron Raether, in a discussion on consumer breach notices — specifically from Ron's perspective as a...more

More Privacy, Please - October 2022

Editor’s Note: In the U.S. laws and regulation space, the White House is focusing on privacy, evident through its session on accountability for big tech and the recent executive order highlighting cybersecurity risks....more

CISA’s Expanded Authority and Federal Requirements: Time for Energy, Water, and Other Critical Infrastructure to Recharge Their...

Critical Infrastructure Must Soon Report Cyber Incidents to CISA Immediately - In March, President Biden signed the “Cyber Incident Reporting for Critical Infrastructure Act” (CIRCIA) into law. CIRCIA applies to the...more

Privacy and Data Security Update - The Consumer Finance Podcast [Audio]

Please join Consumer Financial Services Partner Chris Willis and his colleagues Ron Raether and Kim Phan, partners in our Privacy + Cyber Practice Group, as they discuss recent privacy and data security updates in the...more

Deadline for New UK Contract Requirements for Personal Data Transfers Is Here (EU and California Deadlines Looming)!

Don't Hyperventilate. There are new United Kingdom (UK), European Union (EU), U.S., and global regulatory requirements that just went into effect or will be effective before or soon after year-end that will impact contracts...more

Piecing It All Together: OFAC Combines Seven Years of Regulations, Amendments, and Interpretations All in One

Your business was hit with a ransomware attack over the weekend, and the critical systems are locked up (i.e., encrypted). To unlock those valuable systems and continue operating the business, the threat actor demands...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

New York Department of Financial Services Proposes Amendments to Its Cybersecurity Regulation

On July 29, New York State’s Department of Financial Services (NYDFS) released draft amendments (Draft Amendments) to its Part 500 Cybersecurity Regulation for financial service companies that, among others things: (1)...more

CFPB Turns Its Attention to Data Security

On August 11, the Consumer Financial Protection Bureau (CFPB) published a circular, answering the question “Can entities violate the prohibition on unfair acts or practices in the Consumer Financial Protection Act (CFPA) when...more

More Privacy, Please - August 2022

Editor’s Note: In the U.S. laws and regulation space, federal lawmakers continued to push the American Data Privacy and Protection Act forward, and the FTC pledged to enforce the law against the illegal use of highly...more

Simplifying a Complicated Process — Four Steps to Comply with China’s PIPL New Security Assessment Requirements for Cross-Border...

Background on the PIPL Security Assessment. On July 7, China’s top regulator, the Cyberspace Administration of China (CAC), released the final version of the Measures for Security Assessment of Data Exports (Security...more

More Privacy, Please - July 2022

Editor’s Note: In the U.S. laws and regulation space, federal lawmakers formally introduced bipartisan comprehensive federal privacy legislation titled, the American Data Privacy and Protection Act. Meanwhile, California...more

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