News & Analysis as of

Sensitive Personal Information Compliance

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

Jenner & Block

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

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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

ArentFox Schiff

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

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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

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

Kelley Drye & Warren LLP

The Bulk Data Access Rule: What Advertisers Need to Know

On April 11, the Department of Justice issued an extensive set of FAQs on its Bulk Data Access Rule and advised that it ​“will not prioritize civil enforcement actions against any person for violations” of the Rule through...more

The Volkov Law Group

DOJ Issues Data Security Program Requirements (Part I of II)

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Many “good government” initiatives continue to be enacted or implemented on Capitol Hill or in the Executive Branch — notwithstanding changes in political control. While working on Capitol Hill, the bulk of the legislative...more

Mayer Brown

Department of Justice Releases Compliance & Enforcement Guidance on Data Security Program

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On April 11, 2025, the Department of Justice (DOJ) announced additional guidance regarding the implementation of the Final Rule (the “Rule”), Provisions Pertaining to Preventing Access to U.S. Sensitive Personal Data and...more

Ropes & Gray LLP

DOJ Releases FAQs and Compliance Guidance for Final Rule Restricting Flow of Bulk Sensitive Personal Data to China and other...

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On April 11, 2025, the Department of Justice (“DOJ”) released additional detail regarding the Final Rule implementing former President Biden’s Executive Order 14117, “Preventing Access to Americans’ Bulk Sensitive Personal...more

Baker Donelson

DOJ Final Rule Targets Cross-Border Data Transfers: Key Implications for U.S. and Foreign-Owned Companies Operating in the U.S.

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In the final days of the Biden administration the U.S. Department of Justice (DOJ) issued a sweeping set of regulations which are in effect as of yesterday, April 8, 2025. The regulations focus on cross-border data transfers...more

Wiley Rein LLP

March Privacy Forecast: Maryland’s Strict New Privacy Law Takes Effect October 1

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With 13 comprehensive state privacy laws already in effect, the state privacy law landscape is complex. While there are several common threads throughout many of these frameworks that can allow companies to implement a...more

Wiley Rein LLP

New DOJ Restrictions on Cross-Border Data Transactions Take Effect April 8: Ten Questions as Your Business Prepares to Comply

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The U.S. Department of Justice’s (DOJ) sweeping new rule on cross-border data transactions is set to take effect in substantial part next month, with broad implications for companies that transfer U.S. personal data or...more

Akin Gump Strauss Hauer & Feld LLP

Security Requirements and Compliance Obligations in DOJ's Final Rule on Data Transactions

The Department of Justice’s (DOJ) final rule implements President Biden’s Executive Order 14117 of February 28, 2024, on “Preventing Access to Americans’ Bulk Sensitive Personal Data and United States Government-Related Data...more

Akin Gump Strauss Hauer & Feld LLP

DOJ Regulations Will Restrict Data Transactions to Address National Security Concerns

The Department of Justice’s (DOJ) final rule implements President Biden’s Executive Order 14117 of February 28, 2024, on “Preventing Access to Americans’ Bulk Sensitive Personal Data and United States Government-Related Data...more

Venable LLP

DOJ Issues Final Rule on Bulk Sensitive Personal Data

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On January 8, 2025, the Department of Justice (DOJ) published in the Federal Register a Final Rule, "Preventing Access to U.S. Sensitive Personal Data and Government Related Data by Countries of Concern or Covered Persons,"...more

Dorsey & Whitney LLP

Justice Issues Final Rule Restricting Transfer of Personal U.S. Data to Countries of Concern, Effective in April 2025

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The U.S. Department of Justice (“DOJ”) published its final rule (“Final Rule”) on January 8, 2025, that will prohibit or restrict transfer of certain data of U.S. persons to countries of concern, including to China. The Final...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

New York Amends Data Breach Notification Law to Enhance Notification Requirements, Expand Definition of ‘Private Information’

On December 24, 2024, New York Governor Kathy Hochul signed into law amendments to New York’s private-sector data breach notification law (General Business Law § 899-aa) and government agency data breach notification law (New...more

Bass, Berry & Sims PLC

New Year, New Privacy Laws!

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States continued to pass comprehensive consumer privacy laws throughout 2024. 2025 brings eight new state-level comprehensive consumer privacy laws into effect. As with the five state privacy laws that went into effect in...more

Ropes & Gray LLP

DOJ Issues Final Rule Restricting Flow of Bulk Sensitive Personal Data to China and Other Countries of Concern

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On January 8, 2025, the Department of Justice (“DOJ”) published its Final Rule to implement President Biden’s Executive Order 14117, “Preventing Access to Americans’ Bulk Sensitive Personal Data and United States...more

King & Spalding

DOJ Issues Final Rule Restricting Foreign Access to U.S. Data

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The rule imposes substantial new diligence, reporting, cybersecurity, and auditing obligations on companies. On December 27, 2024, the U.S. Department of Justice (“DOJ”) issued a final rule implementing Executive Order...more

Mayer Brown

US China Trade Monthly - December 2024

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As global economic and geopolitical environments enter a new era, companies need to continuously develop and adjust their coherent global business strategies to secure and further expand business opportunities in all markets...more

Health Care Compliance Association (HCCA)

Disclosure of Full Record to Employer Results in $35K Fine, Broad CAP; Echoes of 2017 HIV Case

It’s not immediately obvious why someone would want to disclose a health care test result as part of a job application. But one such request spurred a Pennsylvania entity to provide a lot more than that: it sent her whole...more

Skadden, Arps, Slate, Meagher & Flom LLP

Fortifying US Data: Proposed Rule Would Establish a New Regime To Restrict or Prohibit Certain Data Transactions With Countries of...

On October 29, 2024, the U.S. Department of Justice (DOJ) published a proposed rule (Proposed Rule) that would restrict or prohibit certain transactions with China, Russia and other countries of concern involving U.S....more

Holland & Knight LLP

FTC Cracks Down on Selling Sensitive Location Info, Restricts Use of Consumer Data for 1st Time

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The Federal Trade Commission (FTC) announced two significant enforcement actions last week – one against data broker Mobilewalla, Inc. and the other against data analytics provider Gravy Analytics, Inc. (and its subsidiary...more

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