News & Analysis as of

Department of Justice (DOJ) Data Security

Venable LLP

A Closer Look at the Data Security Requirements in DOJ's Bulk Data Rule

Venable LLP on

As described in an earlier alert, the Department of Justice (DOJ) recently announced a 90-day pause in enforcement of the "Bulk Data Rule" for entities engaging in good faith compliance. That 90-day grace period ends on July...more

Robinson+Cole Data Privacy + Security Insider

Clock Ticking: DOJ’s New Data Security Rule Requires Compliance by July 8

U.S. companies are running out of time to comply with a sweeping new Department of Justice (DOJ) rule that limits sharing sensitive personal data with certain foreign countries—including China, Russia, and Iran. With a hard...more

Baker Donelson

DOJ Bulk Data Rule: Key Takeaways for Healthcare and Life Sciences

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The Data Security Program (DSP), implemented by the Department of Justice's National Security Division (DOJ/NSD) under Executive Order 14117 (Preventing Access to Americans' Bulk Sensitive Personal Data and United States...more

Wyrick Robbins Yates & Ponton LLP

The Justice Department’s New Rule on Access to U.S. Sensitive Personal Data and Government-Related Data by Countries of Concern or...

On April 8, 2025, the Department of Justice’s new rule on Access to U.S. Sensitive Personal Data and Government-Related Data by Countries of Concern or Covered Persons took effect. The rule, referred to by DOJ as the Data...more

Holland & Knight LLP

U.S. Health Data Affected by New National Security Restrictions on International Data Transfers

Holland & Knight LLP on

Health Insurance Portability and Accountability Act (HIPAA)-covered entities and business associates should be familiar with restrictions on the use or disclosure of protected health information (PHI) under HIPAA rules....more

Orrick, Herrington & Sutcliffe LLP

UPDATE: DOJ Issues Bulk Sensitive Data Rule Guidance, Requirements Go into Effect: What Companies Need to Know

On April 11, 2025, the Department of Justice’s (DOJ) National Security Division (NSD) released an Implementation and Enforcement Policy, a Compliance Guide, and a list of over 100 Frequently Asked Questions (FAQs) to help...more

Jenner & Block

Client Alert: Myth Busters: Dispelling Common Misconceptions of the Department of Justice’s Data Security Program

Jenner & Block on

A month has passed since the Department of Justice (DOJ) National Security Division’s (NSD) issued its Final Rule prohibiting certain transactions involving US government data and Americans’ bulk sensitive personal data....more

Eversheds Sutherland (US) LLP

Navigating new compliance requirements for DOJ’s Bulk Data Rule

While the US federal government is largely scaling back its rulemaking and compliance efforts, one critical exception is where personal data and technology intersect with national security. Exemplifying this trend, on April...more

Seward & Kissel LLP

DOJ Implements New Data Security Program: Data Transfer Restrictions with a National Security Focus

Seward & Kissel LLP on

Effective as of April 8, 2025, the National Security Division of the U.S. Department of Justice (DOJ) has implemented a Data Security Program (the DSP) to address national security risks associated with the transfer of...more

Porter Hedges LLP

DOJ Issues Data Security Program Compliance Guide

Porter Hedges LLP on

On April 11, 2025, the U.S. Department of Justice’s National Security Division (NSD) issued a Compliance Guide to provide additional information to assist companies and individuals in complying with the NSD’s Data Security...more

Venable LLP

DOJ Data Security Program Key Developments: A 90-Day "Good Faith" Extension, Compliance Guide, and Extensive FAQs

Venable LLP on

On April 11, the Department of Justice's National Security Division (NSD) published new guidance on recent measures to restrict the ability of adversarial foreign governments and other foreign entities of concern to access...more

Faegre Drinker Biddle & Reath LLP

Data Security Program, Medicare Advantage, Colorado Insurance Requirements & More

This month’s briefing covers DOJ’s approach to implementing its final rule on what’s now called the Data Security Program. The Trump administration also published a final rule on Medicare Advantage (MA), choosing not to...more

Perkins Coie

DOJ’s Bulk Personal Data Rule Becomes Effective–Resources for Compliance

Perkins Coie on

The new Department of Justice (DOJ) rule governing international transfers of Americans’ information, codified at 28 C.F.R. Part 202, became effective on April 8, 2025....more

ArentFox Schiff

Navigating the DOJ’s New Data Transfer Rule: Implications and Compliance Requirements

ArentFox Schiff on

On January 8, the US Department of Justice (DOJ) issued a final rule under Executive Order 14117, which established the Rule Preventing Access to US Sensitive Personal Data and Government-Related Data by Countries of Concern...more

Baker Donelson

DOJ Final Rule Applies to Anonymized, Pseudonymized, and De-Identified Data: What Data Licensors Need to Know

Baker Donelson on

What's Changed? The U.S. Department of Justice (DOJ) published a Data Security Program (DSP), pursuant to a final rule (Final Rule), which became effective on April 8, 2025....more

Jackson Lewis P.C.

DOJ New Data Transfer Rule Impacts Hiring Practices, Business Operations, and Vendor Management: Time to Review Your Privacy +...

Jackson Lewis P.C. on

U.S. organizations should carefully review and ensure their privacy and cybersecurity practices comply with a wide-ranging new federal rule establishing data transfer restrictions regarding sensitive U.S. personal data. The...more

White & Case LLP

DOJ Issues Guidance on Bulk Sensitive Data Rules

White & Case LLP on

On April 11, 2025, the Department of Justice (DOJ) issued guidance (Guidance) to assist individuals and entities in coming into compliance with its final rule, referred to as the "Data Security Program" (DSP Rule), which...more

Womble Bond Dickinson

DOJ’s Data Security Program Final Rules Effective - Implications for Telecom Providers

Womble Bond Dickinson on

On January 8, 2025, the U.S. Department of Justice (DOJ) issued its final rule to implement Executive Order 14117 aimed at preventing access to Americans' bulk sensitive personal data and government-related data by countries...more

The Volkov Law Group

Episode 366 -- DOJ Issues Data Security Program Requirements

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Could your routine data transfers now violate federal law? The DOJ’s new Data Security Program (DSP) targets the flow of U.S. sensitive personal and government data to foreign adversaries — and the clock is ticking. In this...more

Pillsbury Winthrop Shaw Pittman LLP

DOJ Releases Its Data Security Program Compliance Guide

The guide outlines the requirements of a newly implemented Data Security Program designed to prevent China, Russia and other foreign adversaries designated by the U.S. Department of Justice from accessing American’s sensitive...more

The Volkov Law Group

DSP Compliance: DOJ Sets July 8, 2025 Deadline (Part III of III)

The Volkov Law Group on

As if legal and compliance professionals had enough responsibilities on their plates, DOJ dropped another shoe (to join the tariffs, sanctions and export controls, and immigration issues) and upped the stakes for ethics and...more

Clark Hill PLC

DOJ implements new rule restricting bulk transfers of sensitive personal data

Clark Hill PLC on

On April 22, FTC Commissioner Melissa Holyoak delivered the opening keynote at the IAPP Global Summit, where she emphasized the importance of vigorously enforcing privacy laws while warning against stretching the FTC’s...more

Latham & Watkins LLP

DOJ Data Security Program Now in Effect: Top Takeaways

Latham & Watkins LLP on

New DOJ guidance helps companies understand their obligations under the DSP, which could severely impact investment agreements and ordinary commercial data transactions. On April 11, 2025, the US Department of Justice...more

Baker Donelson

DOJ Issues Additional Guidance and Clarification on the Bulk Data Transfer Rule: What U.S. Businesses Need to Know

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On April 11, 2025, the Department of Justice's National Security Division (NSD) issued additional guidance to assist U.S. organizations in understanding and complying with the Data Security Program (DSP). As discussed in our...more

The Volkov Law Group

Practical Issues and the New DSP (Part II of III)

The Volkov Law Group on

Like any new regulatory and enforcement scheme, companies face a number of new risks that require understanding.  The DSP framework is new, comprehensive and raises significant risks and requires careful design and...more

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