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FTC Articulates Consumer Privacy Concerns – Potential Misuse of Biometric Information and Technologies

On May 18, 2023, the Federal Trade Commission (FTC) issued a policy statement warning that the proliferation of technologies that use or claim to use biometric information may bring risks with regard to consumer privacy and...more

New Washington Law Has Broad Implications For Protecting Consumer Health Data - Landmark ‘My Health My Data’ Act Reaches Beyond...

On April 27, 2023, Washington Governor Jay Inslee signed into law the My Health My Data Act (the "Act"), which will regulate the collection, use, and disclosure of "consumer health data" ("Consumer Health Data" or "CHD"). The...more

Recent Decisions Interpreting Illinois Biometrics Law Could Create "Ruinous Liability"

One can scarcely browse the internet without encountering a story on the use of Artificial Intelligence (AI) by businesses or websites. While recently most attention has focused on generative AI and the increasing use of chat...more

FCC Proposes New Rules for CPNI Data Breach Reporting

The Federal Communications Commission ("FCC" or "Commission") has released its long-awaited Notice of Proposed Rulemaking ("NPRM") proposing to revise data breach reporting requirements for telecommunications carriers and...more

FTC Sues Data Broker Over Sales of Geolocation Data

On August 29, 2022, the Federal Trade Commission (FTC) announced it had filed a complaint in Idaho federal district court against Kochava Inc., a data broker, seeking injunctive relief on account of alleged violations of...more

FTC Issues Advance Notice of Proposed Rulemaking on Commercial Surveillance and Data Security

The Federal Trade Commission (FTC) may have just taken its first steps towards the creation of generally applicable federal privacy and security rules. On Aug. 11, 2022, the FTC published an advance notice of proposed...more

Privacy in a Post-Roe World: What Businesses of All Types Should Consider

Following the U.S. Supreme Court's decision in Dobbs v. Jackson Women's Health Organization overruling Roe v. Wade, businesses and organizations that process personal data—including those outside the health or reproductive...more

And Utah Makes 4—Beehive State Passes Consumer Privacy Law (UPDATED)

Update March 31, 2022: Utah Governor Spencer Cox signed the bill into law March 24, 2022. With passage of the Utah Consumer Privacy Act (UCPA), Utah will become the fourth state to adopt omnibus consumer privacy...more

NIST - Two Guidance Documents for Developing Trustworthy AI

On March 16 and 17, 2022, the National Institute of Standards and Technology (NIST) released two documents as part of its effort to establish a voluntary framework for developing trustworthy and responsible artificial...more

And Utah Makes 4—Beehive State Passes Consumer Privacy Law

With passage of the Utah Consumer Privacy Act (UCPA), Utah will become the fourth state to adopt omnibus consumer privacy legislation—following California, Virginia, and Colorado— when Utah Governor Spencer Cox signs the...more

KIDS Act Seeks to Expand Online Protections for Children Under 16

On September 30, 2021, Senators Ed Markey (D-MA) and Richard Blumenthal (D-CT) and Representative Kathy Castor (D-FL) introduced S.2918, the Kids Internet Design and Safety (KIDS) Act, which would expand online protections...more

Does the U.S. Need an AI "Bill of Rights"?—White House Says "Yes"

The White House Office of Science and Technology Policy (OSTP) announced a plan to develop a "bill of rights" to protect against what the OSTP perceives to be potentially harmful consequences of AI, including anticipated and...more

New York City Biometrics Law Takes Effect in July 2021

Following the municipal ban on the use of facial recognition technology in Portland, Oregon, New York City's more expansive "biometric identifier information" law, set to go into effect July 9, 2021, will ban the sale of...more

European Commission Proposes Sweeping New Regulatory Schema for "High-Risk" AI Systems

The European Commission's (Commission) proposal for regulations establishing harmonized rules on artificial intelligence systems and applications (AI Regulations) reflects aggressive and sweeping proposals to regulate...more

Acting FTC Chair Signals AI-Related Enforcement Priorities

In opening remarks at the Future of Privacy Forum, Acting Federal Trade Commission (FTC) Chairwoman Rebecca Kelly Slaughter previewed several artificial intelligence (AI)-related enforcement priorities under the Biden...more

Acting FTC Chair Signals Potential Enforcement Priorities: Privacy and AI

In opening remarks at the Future of Privacy Forum, Acting Federal Trade Commission (FTC) Chairwoman Rebecca Kelly Slaughter previewed enforcement priorities under the Biden Administration. Slaughter's speech marked her first...more

FTC Sets Its Eye on Algorithms, Automated Tech, and AI-Enabled Applications

Two recent Federal Trade Commission (FTC) enforcement actions reflect increased scrutiny of companies using algorithms, automated processes, and/or AI-enabled applications. In January 2021, the agency announced it had settled...more

Portland Becomes First Jurisdiction to Ban Certain Uses of Facial Recognition by Private Businesses

In an effort to ameliorate the potential discriminatory impact of facial recognition technologies on people of color, women, and other groups, Portland, Ore., recently joined a growing number of jurisdictions limiting the use...more

WA Notify COVID-19 Exposure Tracking Tool Poses Privacy and Implementation Considerations for Employers

Washington State has a new COVID-19 exposure-notification smartphone tool, WA Notify. Introduced on Nov. 30 by the Department of Health, University of Washington, and Brotman Baty Institute, WA Notify has since been...more

2020 State Consumer Privacy Law Round-Up

As the year draws to a close, it seems safe to declare that 2020 was not a good year for the enactment of state consumer privacy legislation. Below, we provide status updates on state privacy task force initiatives and...more

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