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
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
The AI application ChatGPT quickly became a household name, but already is morphing into a more advanced version of generative AI. At the same time, Microsoft’s redesigned Bing search engine will soon run on a new,...more
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
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
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
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
Our discussion examines the FTC’s Advanced Notice of Proposed Rulemaking relating to what it describes as “commercial surveillance” and the CFPB’s circular confirming that covered persons and service providers may violate the...more
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
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
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
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
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