On August 31, the California assembly passed SB1223, which amends the CCPA/CPRA to include “neural data” as a type of sensitive data. SB1223, which is likely to become law, defines “neural data” as “information that is...more
Health and Human Services (“HHS”) released updated guidance yesterday on the use of online tracking technologies (like cookies, pixels, software development kits (SDKs), etc.) by HIPAA Covered Entities (the “Updated...more
Neurotechnology, like wearable EEG headbands and invasive brain implants, collects information from electrical nerve impulses and brain waves derived from your brain, spinal cord, or nervous system. This information, or...more
On July 20, 2023, the Office for Civil Rights (“OCR”) of the U.S. Department of Health and Human Services (“HHS”), and the Federal Trade Commission (“FTC”) published a joint letter sent to approximately 130 hospital systems...more
Our Privacy, Cyber & Data Strategy, Consumer Protection/FTC, and Health Care Teams examine the Federal Trade Commission’s continued focus on consumer privacy in the digital health care space....more
In recent weeks, FTC and HHS have announced expansion of the operational areas of their organizations that are dedicated to enforcement of laws and regulations related to technology, privacy, and cybersecurity....more
Our Privacy, Cyber & Data Strategy and Consumer Protection/FTC Teams analyze the FTC’s first-ever enforcement of its Health Breach Notification Rule and how the FTC is scrutinizing how companies share consumers’ online health...more
On August 24, 2022, California Attorney General Rob Bonta announced a $1.2 million dollar settlement with Sephora to account for alleged violations of the California Consumer Privacy Act (CCPA). This is the first CCPA...more
On April 14, 2021, the U.S. Department of Labor announced new cybersecurity guidance for plan sponsors, plan fiduciaries, record-keepers, and plan participants. The guidance is specifically “directed at plan sponsors and...more