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Texas Mini-TCPA Law – FAQs for Marketing Texts

As we reported earlier this summer, a bill (S.B. 140) was recently enacted in Texas that amends the state’s telemarketing law (TX BUS & COM T.10, Chap. 301-306) to 1) expand the definition of ​“telephone solicitation” to...more

Texting Lawsuits in Washington – A Reminder About State Laws

Most businesses that send texts to their target audiences are focused on compliance with the federal Telephone Consumer Protection Act (TCPA) – and understandably so, given the explosion in class action litigation stemming...more

CPRA Rule Revisions Unlikely to be Finalized in 2022

Just two months before the effective date (January 1, 2023) of the California Privacy Rights Act (“CPRA”), the California Privacy Protection Agency (“CPPA”) Board met on October 28 and 29 to discuss revisions to the agency’s...more

The FTC’s Privacy Rulemaking: Broad and Far-Reaching, but Unlikely to Lead to a Rule Anytime Soon

On August 11, the FTC finally launched its “commercial surveillance and data security” rulemaking after many months of hype and speculation about the FTC’s ability to address consumer privacy through its “Mag-Moss” rulemaking...more

New California Draft Privacy Regulations: How They Would Change Business Obligations and Enforcement Risk

On Friday May 27, 2022, the California Privacy Protection Agency (CPPA) Board announced its next public meeting will be on June 8, 2022. The announcement simply stated the date of the meeting, that there are “some discussion...more

Ten Percent and Rising: Connecticut Becomes Fifth U.S. State to Enact Privacy Law

On Tuesday, Connecticut became the fifth state to pass comprehensive privacy legislation when Governor Ned Lamont signed “An Act Concerning Personal Data Privacy and Online Monitoring” into law. Connecticut joins California,...more

CPRA Update: California Legislature Makes Technical Changes to CPRA

Last week, California’s Governor Gavin Newsom signed into law AB 694, which makes a few technical changes to the California Privacy Rights Act (CPRA). The relevant changes to the CPRA are summarized below....more

TCPA FCC Petitions Tracker - September 2021

Kelley Drye’s Communications Practice Group presents this tracker of active Telephone Consumer Protection Act (“TCPA”) petitions before the Federal Communications Commission (“FCC”). With the recent increase in litigation...more

Health and Fitness Apps and IoT Technologies Should Take Note: FTC Expands Interpretation of its Health Breach Notification Rule

In an aggressive expansion of its security and privacy enforcement programs, on September 15, 2021, the FTC issued what it characterized as a “Policy Statement” reinterpreting an old rule about personal health records....more

CCPA Update: California AG Releases List of Enforcement Actions 

The California Office of the Attorney General has published a list of recent CCPA enforcement examples on its website. Each example summarizes the AG’s allegation of noncompliance and the steps that the companies took to...more

CPRA Update: How to Prepare for Privacy Compliance as an Employer

Last year’s voter guide to California Proposition 24, the California Privacy Rights Act (CPRA), included a stark argument against enacting the privacy ballot initiative because it did not go far enough to protect employee...more

Key Developments in CCPA Litigation for Q1 2021

As we move deeper into the second year of CCPA litigation, the substantive issues continue to develop and we remain focused on the patterns and implications of recent filings and rulings. In this post, we highlight notable...more

Two’s Company: Virginia Has a Comprehensive Data Privacy Law

On March 2, Governor Ralph Northam signed the Virginia Consumer Data Protection Act (VCDPA) into law, making Virginia the second state to enact comprehensive privacy legislation. With the VCDPA on the books, companies have...more

CCPA Litigation Round-Up: Q3 & Q4 2020

It has been a full year since the California Consumer Privacy Act (“CCPA”) took effect at the top of 2020. In the cases filed in the second half of the year, the complaints more frequently assert a violation of the CCPA as a...more

California Privacy Legislation Round-Up: Gov. Newsom Signs CCPA Employee Exemption Extension, Vetoes Others

Prior to the September 30 deadline to sign or veto legislation, California Governor Gavin Newsom recently took action on three bills related to data privacy. Bringing some potential certainty to the dynamic CCPA landscape,...more

Sixth Circuit Holds That Stored-Number Systems Meet the TCPA’s Definition of an Autodialer, Deepening Circuit Split to be...

It has been more than two years since the D.C. Circuit found the Federal Communications Commission’s (the “FCC”) discussion of predictive dialers and other equipment alleged to be an automatic telephone dialing system...more

Lessons Learned for Maintaining Attorney-Client Privileged Data Breach Investigation (and other Consultant) Reports

Following a data breach, companies generally launch an investigation to determine the source and scope of the breach. These efforts are often led by in-house privacy, compliance, and/or litigation counsel with an eye firmly...more

CCPA Update: Final Regulations Submitted but No Changes from Prior Draft

On June 2, California Attorney General Xavier Becerra announced that he had submitted final CCPA regulations to the Office of Administrative Law (OAL) for review. The final regulations are substantively identical to the...more

The CCPA Non-Discrimination Right, Explained

The California Consumer Privacy Act (CCPA) provides consumers with a right to non-discrimination when they exercise other privacy rights guaranteed by the law, such as the right to access, delete, or opt out of the sale of...more

CCPA Litigation Round-Up

The California Consumer Privacy Act (CCPA) took effect January 1, 2020. While the California Attorney General’s enforcement authority is delayed until July 1, private litigants have already started to file direct claims...more

Facial Recognition Tech Enforced by Vermont AG Under State Privacy & Data Broker Laws

Vermont Attorney General Thomas Donovan Jr. has ratcheted up ongoing scrutiny of facial recognition technology. On March 10, the Vermont AG sued facial recognition technology provider Clearview AI and moved for a preliminary...more

CCPA Update: Attorney General Releases Third Draft of Proposed CCPA Regulations

On Wednesday, the California Attorney General (AG) released a third draft of proposed CCPA regulations for public comment. The draft contains a series of technical corrections, along with a handful of substantive incremental...more

What Does Brexit Mean for Privacy Shield?

Three and a half years after UK citizens voted to leave the EU, the country officially left the Union on January 31. One of the many questions resulting from the departure is what happens to the EU-U.S. Privacy Shield as it...more

CCPA Update: Attorney General Proposes Modified Draft Regulations

On Friday, California Attorney General Xavier Becerra released proposed modifications to the formerly-released draft regulations implementing the California Consumer Privacy Act (CCPA). The modifications reflect the Attorney...more

CCPA Implementation: An Early Map

The January 1, 2020 effective date of the California Consumer Privacy Act (CCPA) has come and gone, but questions about how to comply with the law show no hint of disappearing. As companies move past their efforts to comply...more

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