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Understanding Access vs. Acquisition - Dear Mary – Incidents + Investigations Cybersecurity Advice Column

Each of the 50 states has its own definition of what constitutes a reportable data breach. For some, it requires “unauthorized access” to personal information. For others, it requires “unauthorized acquisition.” And then,...more

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

New Hampshire Enacts Comprehensive Privacy Law – SB 255

On March 6, 2024, New Hampshire Governor Chris Sununu signed Senate Bill 255 into law, making New Hampshire the 14th U.S. state to enact a comprehensive privacy law. The law, which becomes effective on January 1, 2025, is...more

More Privacy, Please – February 2024

Editor’s Note: In recent regulatory and enforcement developments, the White House announced a new executive order aimed at strengthening cybersecurity at U.S. ports, and another executive order was issued to protect sensitive...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

The Garden State Joins the Privacy Party

On January 16, New Jersey Governor Phil Murphy signed S332 (the act), making New Jersey the first state in 2024 to enact a comprehensive privacy law. Several other states are currently considering similar comprehensive...more

FTC's Sensitive Location Privacy Collection and Sale Expectations: Insights From Data Broker Settlements (and 10 Action Items to...

Following several years of investigating the common practices in the space, the Federal Trade Commission (FTC) reached its first settlement with a data broker over the alleged collection and sale of location information that...more

More Privacy, Please – July 2023

Editor’s Note: Texas, Oregon, and Delaware became the latest states to pass a comprehensive privacy bill, while the CPRA, Connecticut, and Colorado’s privacy laws came into force. In the litigation world, the FTC filed an...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

More Privacy, Please - May 2022

Editor’s Note: Connecticut became the fifth state in the nation to successfully pass a comprehensive privacy bill (now awaiting its governor’s signature), following California, Colorado, Utah, and Virginia. Meanwhile,...more

Connecticut Legislature Passes Comprehensive Privacy Legislation, Awaiting Governor’s Signature

On April 28, the Connecticut House passed Senate Bill 6, an act concerning personal data privacy and online monitoring (SB 6 or Connecticut Act). The Senate unanimously passed SB 6 on April 20, and is now currently under...more

A Fresh "Face" of Privacy: 2022 Biometric Laws

Introduction: Biometric Laws in 2022 - In the first quarter of 2022 alone, no fewer than seven states have introduced biometric laws — California, Kentucky, Maine, Maryland, Massachusetts, Missouri, and New York — generally...more

US and Europe Issue Joint Statement Announcing Agreement on New Trans-Atlantic Data Privacy Framework to Replace EU-US Privacy...

On March 25, a huge sigh of relief was heard from businesses and organizations located throughout the United States and Europe after the U.S. and European Commission announced their agreement in principle on a new...more

UK Releases Three New Documents Clarifying International Data Transfers

On January 28, following the European Commission’s June 4, 2021 issuance of modified standard contractual clauses (SCCs), the United Kingdom’s (U.K.) secretary of state for digital, culture, media, and sport, presented the...more

U.K. Supreme Court Finds Data Protection Representative (I.e., Class) Action Cannot Be Pursued Against Google

On November 10, the United Kingdom (U.K.) Supreme Court issued a decision in Lloyd v. Google LLC, UKSC2019/0213 (Supreme Court of the United Kingdom), recognizing that the loss of control of personal data by consumers alone...more

More Privacy, Please - October 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

The Uniform Personal Data Protection Act: A New Approach to Scoping

This July, the Uniform Law Commission (ULC) approved a final draft of the Uniform Personal Data Protection Act (UPDPA). The ULC is a nonpartisan group, which drafts model laws with the goal of widespread state adoption. One...more

U.S. Senators Reintroduce Privacy Legislation

In recent months, updated versions of the Data Protection Act of 2020 and the SAFE DATA Act have been reintroduced in the U.S. Senate. This post provides an overview of these updated privacy bills, both of which were...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

Colorado Passes Comprehensive Data Privacy Law

On June 8, the Colorado legislature passed the Colorado Privacy Act (CPA). Assuming Governor Jared Polis signs the bill into law within 30 days, as is expected, Colorado will become the third state in the United States to...more

Data Compliance Issues for Cos. Making, Using Vaccine Apps

For most of 2020, the world struggled with COVID-19 and its effects. Earlier in the pandemic, we published a Law360 guest article offering privacy guidance to developers interested in creating contact-tracing...more

CCPA Enforcement Area No. 1 - The Infamous "Do-Not-Sell" Button

Enforcement of the California Consumer Privacy Act (CCPA) began July 1, 2020. Our privacy team at Troutman Pepper includes several attorneys who worked in an attorney general’s office. This privacy regulatory team has...more

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