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FTC Authorizes use of Compulsory Process in AI Investigations

On November 21, the Federal Trade Commission (“FTC”) approved in a 3-0 vote a resolution authorizing the use of compulsory process in nonpublic investigations involving products and services that involve or claim to involve...more

FTC Announces New Safeguards Rule Breach Notification Requirements

On October 27, the Federal Trade Commission (“FTC”) unanimously voted to amend the Safeguards Rule to require non-banking financial institutions to report data breaches and security events to the Agency. This amendment will...more

CPPA publishes new draft regulations addressing AI, risk assessments, cyber audits

The California Privacy Protection Agency (CPPA) recently published two new sets of draft regulations addressing a range of cutting-edge data protection issues. Although the CPPA has not officially started the formal...more

CPPA Publishes New Draft Regulations Addressing AI, Risk Assessments, and Cyber Audits

The California Privacy Protection Agency (CPPA) recently published two new sets of draft regulations addressing a range of cutting-edge data protection issues. Although the Agency has not officially started the formal...more

Texas Adds a Wrinkle to State Privacy Law Patchwork

On May 28, Texas became the sixth state this year to pass a comprehensive data protection law. Although the Texas Data Privacy and Security Act (“TDPSA”) is largely in line with the Virginia Consumer Data Protection Act and...more

California Enforcement Sweep Targets Mobile Apps

On Friday, January 27, California Attorney General Rob Bonta announced an investigative sweep of businesses that provide mobile apps, issuing warning letters to those that AG Banta alleges failed to comply with the California...more

2023 Privacy and Data Security Preview

2022 proved to be an historic year for privacy and data security. Connecticut and Utah joined the list of states that have now passed comprehensive data privacy laws, bringing the total to five (5) states. For the first...more

FTC requires data minimization in Drizly enforcement action

In a recent enforcement action against online alcohol delivery service Drizly and its CEO, James Rellas, the Federal Trade Commission (FTC) made clear its focus on data minimization and limitations on the secondary uses of...more

CPPA Publishes Updated Draft CPRA Regulations

On October 17, the California Privacy Protection Agency (“CPPA”) published the first revisions to the CPRA regulations. This draft includes an extensive list of proposed changes in advance of the CPPA Board public hearing,...more

CPRA’s Employee and B2B Exemptions Appear Destined to Sunset

The August 31 closing of the California legislative session likely marked the end of hopes for an extension of the limited exemptions for employee and business-to-business (B2B) data that have existed for the California...more

FTC Takes Aim at “Commercial Surveillance”

In an active week for federal regulators, the Federal Trade Commission (FTC) joined the CFPB in announcing important initiatives that may change privacy and data security practices in major ways....more

CPPA Announces Public Hearing on CPRA Regulations

The California Privacy Protection Agency announced today that it began the formal rulemaking process to adopt the proposed regulations implementing the Consumer Privacy Rights Act of 2020 (“CPRA”).  As part of this...more

Draft CPRA Regulations Released by CPPA

The California Privacy Protection Agency (“CPPA”) scheduled a Board Meeting for June 8th, in which it will be discussing and possibly taking action with regard to the much anticipated CPRA enforcing regulations. To...more

FTC Chair Announces New Privacy Approach

In a series of recent statements and releases, Lina Khan, the Chair of the FTC, made clear the Commission’s intention to revamp its oversight of consumer data privacy and establish more substantive limits on commercial data...more

SEC Proposes New Disclosure Rules for Cyber Incidents

On March 9, 2022, the SEC proposed a new rule to enhance and standardize disclosures regarding cybersecurity incidents, risk management, strategy, and governance. If approved, public companies subject to the reporting...more

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