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FTC Proposes to Impose Sweeping Restrictions on Tech Company's Ability to Profit From Youth Data

On May 3, 2023, the Federal Trade Commission ("FTC") issued an Order to Show Cause against Meta for alleged violations of Meta's 2012 and 2020 privacy orders and seeks to bar the company from monetizing data related to...more

My Health, My Data: Washington Enacts First State Comprehensive Health Privacy Law

The sweeping law imposes new requirements on the processing and sale of consumer health data in the state. On April 27, 2023, Washington State Governor Inslee signed the "My Health My Data Act" ("Act"). This Act marks the...more

Federal Trade Commission Proposes New Rule Governing Consumers' Ability to Cancel Recurring Subscriptions and Memberships

On March 23, 2023, the Federal Trade Commission ("FTC") announced that it would propose a "click to cancel" provision in its rules governing subscriptions and recurring memberships. According to the FTC, the proposed rule...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

California Is First State to Adopt Age-Appropriate Design Code Law Alert

The California Age-Appropriate Design Code Act expands privacy requirements for businesses with online products, services, or features directed to or likely to be accessed by users under the age of 18....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

With New Proposed Regulations, the California Privacy Protection Agency Begins its Rulemaking

On July 8, the CPPA officially began the formal rulemaking process for new privacy regulations—many of which operationalize new CPRA requirements. With the publication of the Notice of Proposed Rulemaking, the 45-day initial...more

Connecticut Becomes Fifth State to Enact a Comprehensive Data Privacy Law

On May 10, 2022, Connecticut, following Utah, California, Virginia, and Colorado, became the fifth state to adopt a comprehensive consumer data privacy law. On May 10, 2022, Connecticut Governor Ned Lamot signed "An Act...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

Telehealth Awareness Week: Insights on Telehealth

In support of the American Telemedicine Association's Telehealth Awareness Week (September 19-25, 2021), Jones Day's Digital Health team shared key insights on various legal topics applicable to telehealth. Jones Day's...more

California Attorney General Issues Bulletin on Health Data Breach Reporting Requirements

The California Attorney General ("AG") has issued guidance reminding health care providers of their duty to report health care data breaches and to comply with other state and federal data privacy laws....more

Florida Makes Significant Changes to State Telemarketing Laws

Florida law now provides a private right of action for violations of various telemarketing rules, allows the use of certain automated telemarketing methods with prior express written consent, and imposes certain restrictions...more

Colorado Becomes Third State to Enact Comprehensive Data Privacy Law

Introduction  Colorado has joined California and Virginia as the third state with a comprehensive data privacy law. On July 7, 2021, Colorado Governor Polis signed the Act into law, following the Colorado Senate's passage of...more

White House Calls for Federal Reforms in Long-Anticipated Cybersecurity Executive Order

President Biden's Executive Order calls for an extensive reassessment and revamping of the federal government's cybersecurity defenses and incident response capabilities, establishing benchmarks that may inform standards...more

Executive Order Launches Cybersecurity Labeling Regime for Consumer Products

The Biden Administration's Executive Order directs the Department of Commerce and the Federal Trade Commission to establish pilot programs to develop product labels that inform consumers about the cybersecurity capacities of...more

Cybersecurity Executive Order Establishes Framework to Strengthen Cybersecurity Elements of Federal Government Contracts

The Situation: On May 12, 2021, President Biden issued an "Executive Order on Improving the Nation's Cybersecurity," which calls for "bold" and extensive action designed to update and standardize requirements and procedures...more

GSA's Use of DoD Cybersecurity Language for Future Contracts Signals Increased Security Requirements in Civilian Contracts

The General Services Administration ("GSA") is including language regarding cybersecurity requirements in requests for proposals relating to certain IT governmentwide acquisition contracts ("GWACs"). Certain requirements will...more

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