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
On April 2, the California Privacy Protection Agency (CPPA or “the Agency”) issued the Agency’s first-ever enforcement advisory. The advisory (“Applying Data Minimization to Consumer Requests”) reaffirms data minimization as...more
The latest version of the New York (“NY”) State Privacy Law (“S365B”) is continuing to make its way through the NY State Assembly. As readers of this blog know, members of the NY State Senate have been trying to get a version...more
On January 16, Gov. Phil Murphy (D) of New Jersey signed Senate Bill No. 332 into law. The New Jersey privacy law generally follows the same framework found in many of the comprehensive privacy laws enacted by other states...more
The New Jersey Legislature this week passed Senate Bill 332 (SB 332), a comprehensive consumer data privacy bill. Since its conception, the bill has undergone significant revisions that expanded a once narrow bill into a more...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
Keypoint: The Agency proposed more revisions to the CCPA regulations for consideration at the December 8 board meeting. On December 1, 2023, the California Privacy Protection Agency (Agency) published proposed revisions to...more
California continues to be at vanguard of data privacy rights. The latest effort by California legislators to protect consumer privacy rights focuses on data brokers, who under the proposed California Senate Bill 362, aka...more
Under the California Consumer Privacy Act (CCPA), California consumers may exercise certain rights in relation to their personal information – and businesses have strict deadlines to respond to such consumer requests. These...more
Iowa will soon be the sixth state in the nation with a comprehensive consumer privacy law – but the good news for employers is that it does not apply to data collected in the employment context and does not include a private...more
Shortly before Privacy Day, California Attorney General (Cal AG) Rob Bonta announced a California Consumer Privacy Act (CCPA) enforcement sweep that targeted mobile applications....more
Keypoint: The draft CPA rules retain the hallmarks of what makes the CPA rules unique but contain some notable revisions and clarifications. On Friday, January 27, 2023, the Colorado Attorney General’s Office published the...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
The California Privacy Rights Act will go into full effect on January 1. The CPRA is commonly referred to as a “new” act, but is actually an add-on/modification to the California Consumer Privacy Act of 2018, which has been...more
The so-called “HR exemption” taking employee and applicant personal information out of the control of the California Consumer Privacy Act (CCPA) is about to come to an end. Employers who are “businesses” for purposes of the...more
Keypoint: The CPA draft rules are a complex and lengthy set of regulations that, if adopted without substantial modification, will significantly expand the CPA’s requirements and require controllers to carefully consider...more
If you’ve relied on the temporary “exemption” for employee/applicant and business-to-business (B2B) personal information under the California Consumer Privacy Act (CCPA), those exemptions will expire on January 1, 2023. The...more
The California Consumer Privacy Act (CCPA) exemptions for employee and business-to-business Personal Information (PI) likely will not be extended. Aug. 31, 2022 was the last day for each house to pass bills, per the...more
Last week, the California Legislature failed to reach agreement on an extension to the employee exemption which applies to the California Consumer Privacy Act (CCPA) which currently exempts employees and employee data from...more
Keypoint: The California Privacy Protection Agency issued a first set of draft regulations that contain a number of notable provisions but do not address all of the CPRA’s rulemaking topics....more
Keypoint: The CPRA is relatively prescriptive in how organizations must receive and respond to consumer requests, while the CPA and VCDPA introduce an appeal process and other nuances that will require adjusting existing CCPA...more
The Utah legislature has passed Senate Bill 227, otherwise known as the Utah Consumer Privacy Act (UCPA). Barring a veto from Utah Governor Spencer J. Cox, who, as of March 15, 2022, officially has the bill on his desk for...more
On November 3, 2020, California voters approved Proposition 24, a ballot initiative which enacted the California Privacy Rights Act (“CPRA”). The CPRA amends the California Consumer Privacy Act (“CCPA”), the most sweeping...more
Interested parties have until November 8 to submit comments on proposed topics of CPRA rulemaking including new automated decisionmaking, risk assessments, new consumer rights, and sensitive personal information. On...more
Keypoint: The California Privacy Protection Agency initiates preliminary rulemaking activities under the California Privacy Rights Act. On Wednesday, September 22, 2021, the California Privacy Protection Agency (Agency)...more