Under many circumstances, state privacy laws require businesses to pass a consumer’s valid deletion request to any entity that processes the data on behalf of the business or otherwise is a recipient of the data. These...more
The U.S. is taking another swing at a federal data privacy law with the American Privacy Rights Act, or APRA. While there’s no guarantee that the APRA will become the law of the land, it’s still worthwhile to study in order...more
Welcome to this month's issue of The BR Privacy & Security Download, the digital newsletter of Blank Rome’s Privacy, Security & Data Protection practice....more
On January 1, 2023, the California Privacy Rights Act (CPRA) went into full force and effect, heralding a new era of statewide personal information (PI) regulation. The CPRA provides even more protection for California...more
On August 11, 2022, the Federal Trade Commission (FTC) issued an Advance Notice of Proposed Rulemaking (ANPR), titled “Trade Regulation Rule on Commercial Surveillance and Data Security”. The wide-ranging ANPR seeks feedback...more
On March 2, 2021, Virginia Governor Ralph Northam signed into law the Virginia Consumer Data Protection Act (VCDPA), making Virginia the second state, after California, to enact general data privacy legislation. The VCDPA...more
The California Consumer Privacy Act (CCPA)—the most comprehensive personal data privacy legislation anywhere in the United States so far—is officially being enforced. Is your website in compliance? Does it need to be? What...more
As of January 1, 2020, the California Consumer Privacy Act of 2018 (CCPA) is now the law of the land, having gone into effect at the beginning of this year. One of the more complex issues concerning the CCPA pertains to the...more
As more organizations find themselves under scrutiny for the way they collect and use consumer data, maintaining CCPA compliance has never been more important. CCPA has been introduced to give control back to consumers,...more
The California Privacy Rights Act (CPRA) is going to be on the November 3 ballot. The CPRA would amend the California Consumer Privacy Act (CCPA) to provide a greater level of rights for consumers and more stringent...more
With the California Consumer Privacy Act (CCPA) now in effect (January 1, 2020) and enforceable by California’s Attorney General (“AG”) (July 1, 2020), the AG has published Frequently Asked Questions (FAQs). Designed to aid...more
Shook Weighs in on Updated CCPA Regulations - In response to extensive public comment, the California Attorney General’s office released modified draft regulations under the CCPA on February 7. Shook has provided initial...more
As one of the oldest and most recognized data privacy and security practices, we have had the honor of helping dozens of companies set up and evolve their data privacy programs over the past decade. That experience has given...more
The much anticipated California Consumer Privacy Act (“CCPA”) is now in effect (as of January 1, 2020), and as we’ve recently reported, class action litigation under the CCPA has already begun. Organizations should have...more
- The California Attorney General Office (AGO) issued revised proposed regulations (Version 2) regarding the California Consumer Privacy Act on February 7, 2020. The AGO will collect comments on the revised regulations until...more
- The Washington state Senate has passed its version of a consumer data privacy bill as state lawmakers debate proposed legislation for the Washington Privacy Act, the state’s first data privacy law. - In their own bill,...more
Additional draft regulations were issued by the California Attorney General on February 7th and subsequently modified on February 10th. ...more
On February 7, 2020, California Attorney General Xavier Becerra published modified regulations for the California Consumer Privacy Act after reviewing the public comments received on the initial draft regulations. While the...more
California Attorney General Xavier Becerra has released updated regulations to the California Consumer Privacy Act (CCPA) that contain a number of material modifications to the initial CCPA regulations released in October...more
The California Consumer Privacy Act provides some relief to financial institutions, but these carve-outs are not a “get out of jail free” card. Blank Rome’s David Oberly and First National Bank of Long Island’s Tanweer Ansari...more
On January 30, Rep. Kathy Castor (D-FL) introduced H.R. 5703, the Protecting the Information of our Vulnerable Children and Youth Act (Kids PRIVCY Act) that would expand requirements under the Children’s Online Privacy...more
The California Office of the Attorney General has published proposed amendments to the California Consumer Privacy Act (CCPA) draft regulations. The amendments are open for public comment until 5 pm PT on Feb. 24, 2020....more
Many businesses and their service providers have been awaiting final guidance from the California Attorney General concerning the California Consumer Privacy Act (CCPA). When news came last Friday of a regulatory update...more
Keypoint: The modified proposed regulations make substantial changes to the proposed regulations, including modifying how consumer notices must be drafted and changing some of the requirements for receiving and responding to...more
The California Consumer Protection Act (CCPA) went into effect January 1, 2020, though the enforcement of the CCPA is delayed until July 1, 2020. The obligations set forth below will apply to all parties; however, the...more