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CCPA Update: Final Proposed Regulations

On June 1, 2020, the Office of the California Attorney General submitted the final proposed regulations package under the California Consumer Privacy Act (CCPA) to the California Office of Administrative Law (OAL). As...more

The Effective Date of the California Consumer Privacy Act of 2018 Has Come and Gone: What To Do Now?

The CCPA became effective January 1, 2020. Some businesses prepared to meet the deadline, while others have become partially compliant but still have more to do. Some may not have begun. What should a business be doing at...more

CCPA Update: Important Modifications to the Proposed Regulations

As we reported here the California Attorney General released proposed regulations pursuant to the California Consumer Privacy Act (CCPA) on October 10, 2019. These proposed regulations were modified on February 7 and again on...more

CCPA Amendments Are In! Draft CCPA Regulations Are Out!

The long-awaited amendments to the California Consumer Privacy Act of 2018 (CCPA) have finally become law. On October 11, 2019—two days before the October 13 deadline—California Governor Gavin Newsom announced that he signed...more

CCPA Proposed Regulations are Out!

On October 10, 2019, the California Office of the Attorney General (“AG”) published the long-awaited proposed text of the California Consumer Privacy Act Regulations (the “Proposed Regs”). The Proposed Regs provide guidance...more

California Legislature Amends CCPA and Creates Data Broker Registry

On September 13, 2019, the California State Legislature passed several amendments to the California Consumer Protection Act (“CCPA”), which was originally passed in 2018 as a flawed and widely-criticized piece of legislation....more

CCPA Guide: Does Personal Information Include Employee and Employee Benefit Plan Data?

Beginning on January 1, 2020, the California Consumer Privacy Act of 2018 (CCPA) will impose new privacy obligations on certain businesses that collect personal information of California consumers. Employers with employees in...more

CCPA Guide: Are You Covered by the CCPA?

Beginning on January 1, 2020, the California Consumer Privacy Act of 2018 (CCPA) will impose new privacy obligations on certain businesses that collect personal information of California consumers and are (or are jointly with...more

New Hampshire Takes the NAIC Plunge

On August 2, 2019, New Hampshire became the most recent of many states that adopted an Insurance Data Security Law (Senate Bill 194-FN) modeled after the National Association of Insurance Commissioners’ (NAIC) Insurance Data...more

What Every InsurTech Should Know About Privacy and Cybersecurity

As an early stage or startup InsurTech, you’re highly focused on all the right things: identifying a challenge for the insurance industry, developing an innovative technical solution, making it practical and scalable, getting...more

CCPA Guide: Does Personal Information Include Employee and Employee Benefit Plan Data?

Beginning on January 1, 2020, the California Consumer Privacy Act of 2018 (“CCPA”) will impose new privacy obligations on certain businesses that collect personal information of California consumers. Employers with employees...more

CCPA Guide: We Are Covered, So Now What Do We Do? Create a Project Plan!

Effective January 1, 2020, the California Consumer Privacy Act of 2018 (“CCPA”) will impose new privacy obligations on certain businesses that collect personal information of residents of California and are responsible for...more

CCPA Proliferation: Connecticut and other states propose to follow California’s lead on Consumer Privacy

On March 20, 2019, the Joint Committee on Government Administration and Elections (the “Joint Committee”) introduced An Act Concerning Consumer Privacy, Raised Bill No. 1108. The Bill is essentially a reprinting of the...more

CCPA Guide: Are You Covered by the CCPA

Beginning on January 1, 2020, the California Consumer Privacy Act of 2018 (“CCPA”) will impose new privacy obligations on certain businesses that collect personal information of California consumers and are (or are jointly...more

California Amends Consumer Data Privacy Act, but Leaves Material Provisions Unchanged and Questions Unanswered

On August 31, 2018, the California State Legislature passed Senate Bill 1121, amending the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA, which contains the broadest consumer data privacy protections in the...more

South Carolina Department Clarifies Confusing Change in Its New Insurance Data Security Act

As reported on Locke Lord’s InsureReinsure blog, the NAIC adopted a model law for the protection of the data and systems used by the insurance industry, and South Carolina became the first state to enact legislation based on...more

Dropping another Stone in the Pond? California’s New Consumer Privacy Act

California may have again taken the privacy protection lead among U.S. jurisdictions with the Governor’s signing on June 28, 2018 of the California Consumer Privacy Act of 2018 (AB 375) (the “Act”). Privacy and security...more

A Closer Look at the NAIC Insurance Data Security Model Law

Following New York’s lead after the Department of Financial Services (the NYDFS) promulgated its Cybersecurity Regulation, in October 2017 the NAIC adopted its Insurance Data Security Model Law (the NAIC Model) to establish...more

Internal Investigations: The Three C’s – Confidence. Credibility. Cost.

In this issue: - THE THREE C’S — CONFIDENCE, CREDIBILITY AND COST - WHO CONDUCTS THE INVESTIGATION? - SCOPE OF THE INVESTIGATION - MINDSET AT THE OUTSET OF AN INVESTIGATION - THE NEED FOR...more

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