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California Proposes CCPA Amendments to Further Protect Children's Privacy

Proposed amendments to the California Consumer Privacy Act would require businesses to obtain opt-in consent prior to collecting, selling, sharing, using, or disclosing a minor's personal information....more

Executive Order Limits Sale or Transfer of Personal Data to Certain Countries

The U.S. Government has identified the exploitation of Americans' bulk sensitive personal data and U.S. government-related data by "countries of concern" as posing a national security risk....more

HHS Releases Cybersecurity Performance Goals to Enhance Cybersecurity for Health Care and Public Health Sectors

The Department of Health and Human Services ("HHS") has released voluntary cybersecurity performance goals for the health care and public health sectors, which outline an increasingly standardized regulatory approach and...more

California Privacy: A Deeper Dive Into the New Regulations Expected in 2024

The Background: The California Privacy Protection Agency board ("CPPA" or "Board") is in the process of issuing new regulations as authorized under the California Privacy Rights Act. These three sets of proposed regulations...more

The Department of Defense Proposes the Much-Anticipated CMMC 2.0

On December 26, 2023, the Department of Defense ("DoD") published a proposed rule to implement the Cybersecurity Maturity Model Certification ("CMMC") 2.0, which will establish comprehensive cybersecurity requirements for...more

HHS Announces Upcoming Federal Strategies to Enhance Cybersecurity for Health Care and Public Health Sectors

The Department of Health and Human Services ("HHS") has released a concept paper outlining its new cybersecurity strategies for the health care sector, identifying cybersecurity priorities, potential future regulations and...more

FTC Seeks to Strengthen Privacy Protections of Children Online

On December 20, 2023, the Federal Trade Commission ("FTC") announced a Notice of Proposed Rulemaking ("NPRM") to revise the Children's Online Privacy Protection Act ("COPPA") Rule to reduce the amount of information...more

HHS Enters Into First-Ever Ransomware Resolution Agreement and Corrective Action Plan

The U.S. Department of Health and Human Services ("HHS") Office of Civil Rights ("OCR") has entered into its first settlement of potential Health Insurance Portability and Accountability Act ("HIPAA") violations arising out...more

New York Governor Proposes Stringent Cybersecurity Regulations for Hospitals

New York is the first state to propose cybersecurity requirements for all hospitals operating in the state to address patient safety and other cybersecurity related issues....more

FTC Requires Non-Bank Financial Institutions to Report Data Security Breaches Under Amended Safeguards Rule

On Friday, October 27, the Federal Trade Commission ("FTC") announced new amendments to the Safeguards Rule, requiring covered financial institutions to report certain data breaches to the FTC and reflecting its continuing...more

Considerations for Addressing DOJ’s Corporate Compliance Guidance on Mobile Devices and Messaging Platforms

In light of the DOJ’s most recent guidance on the use of personal devices and third-party messaging applications by corporate personnel, this White Paper addresses issues and challenges that companies are facing in this area...more

The Consumer Financial Protection Bureau Announces Sweeping Rulemaking for Companies That Collect and Furnish Personal Data

On August 15, 2023, the Consumer Financial Protection Bureau ("CFPB") announced it was launching a rulemaking aimed at subjecting any company or entity that collects and sells consumer data to the Fair Credit Reporting Act...more

European Union and United States Reach New Agreement for Data Flow Across the Atlantic

On July 10, 2023, the EU Commission adopted its adequacy decision for the EU-U.S. Data Privacy Framework, concluding that the United States ensures an adequate level of protection for personal data transferred from the...more

Iowa Becomes Sixth State to Enact a Comprehensive Data Privacy Law

On March 28, 2023, Iowa—following California, Colorado, Connecticut, Utah, and Virginia—became the sixth state to adopt a comprehensive consumer data privacy law. On March 28, 2023, Iowa Governor Kim Reynolds signed "An...more

Consumer Health Information and Increased Scrutiny: FTC Brings First Action Under Health Breach Notification Rule

The Federal Trade Commission ("FTC") has brought its first enforcement action for violations of the Health Breach Notification Rule ("HBNR"), signaling heightened federal agency scrutiny of digital health platforms,...more

U.S. National Institute of Standards and Technology Releases AI Risk Management Framework

The National Institute of Standards and Technology ("NIST") has released its AI Risk Management Framework ("AI RMF") as a resource to reportedly assist individuals, organizations, and society identify risks associated with...more

California Privacy Protection Agency Modifies its Proposed Regulations

In Short - The Situation: The California Privacy Protection Agency ("CPPA" or "Agency") has modified its proposed regulations implementing many key California Privacy Rights Act ("CPRA") requirements....more

United States Signs Executive Order to Implement EU-U.S. Trans-Atlantic Data Privacy Framework

On October 7, 2022, President Biden signed an executive order on "Enhancing Safeguards for United States Signals Intelligence Activities," outlining the measures that the United States will take to implement its commitments...more

New Security Rules for Organizations Supplying Software to the Federal Government

The OMB has issued memorandum M-22-18 with new security requirements (the "Rules") requiring federal agencies to ensure that all third-party software they use complies with secure software development standards and guidance...more

California Attorney General Signals CCPA Enforcement Priorities in $1.2 Million Sephora Settlement

On August 24, 2022, California Attorney General Rob Bonta announced his office's first privacy enforcement action and settlement against a publicly disclosed entity, Sephora, Inc., for violations of the CCPA, including the...more

Federal Privacy and Data Security Regulation on the Horizon: The FTC Announces Proposed Rulemaking

The Federal Trade Commission announced on August 11, 2022, that it is seeking public comment regarding its Advanced Notice of Proposed Rulemaking on commercial surveillance and data security. The Federal Trade Commission...more

President Biden Signs Cyber Incident Reporting for Critical Infrastructure Act

On March 15, 2022, President Biden signed into law the Cyber Incident Reporting for Critical Infrastructure Act of 2022 (the "Act"), creating new requirements for organizations operating in critical infrastructure sectors to...more

Department of Commerce Seeks Comment on Regulation of IaaS Providers

Regulations will mandate more robust customer identity verification procedures and special measures to combat malicious cyber activities. On September 24, 2021, the Department of Commerce ("Commerce") published an Advance...more

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