Our Privacy, Cyber & Data Strategy Team highlights the shift in priorities for privacy and cybersecurity regulation and enforcement across U.S. agencies under the second Trump Administration....more
On January 15, 2025, the Federal Trade Commission (FTC) announced a proposed settlement with GoDaddy Inc. (GoDaddy) for making false or misleading representations about their security practices in violation of Section 5 of...more
1/22/2025
/ Antitrust Violations ,
Compliance ,
Cybersecurity ,
Data Privacy ,
Data Security ,
Enforcement Actions ,
Federal Trade Commission (FTC) ,
FTC Act ,
Misleading Statements ,
Privacy Laws ,
Risk Management ,
Unfair or Deceptive Trade Practices
With an amendment to its Safeguards Rule, the Federal Trade Commission has joined other federal agencies regulating cybersecurity breaches. Our Privacy, Cyber & Data Strategy Team analyzes how the amendment will affect...more
On October 27, 2023, the FTC approved an amendment to the Safeguards Rule (the “Amendment”) requiring that non-banking financial institutions notify the FTC in the event of a defined “Notification Event” where customer...more
Publications and Advisories - July 31, 2023 – Dave Brown, Kate Hanniford, Kim Peretti, Julia Mediamolle, Cara Peterman, Sierra Shear, Kristen Bartolotta, and Kezia Osunsade published “Securities Law, Securities Litigation,...more
8/10/2023
/ Artificial Intelligence ,
California Consumer Privacy Act (CCPA) ,
Civil Investigation Demand ,
COPPA ,
Cybersecurity ,
Data Privacy ,
Data Protection ,
Federal Trade Commission (FTC) ,
Hackers ,
International Data Transfers ,
Online Safety for Children ,
Popular ,
Ransomware ,
Risk Management ,
Securities and Exchange Commission (SEC) ,
Standard Contractual Clauses ,
Telehealth
In mid-July, the Federal Trade Commission (FTC) reportedly opened an investigation into OpenAI, the maker of ChatGPT, sending the company an extensive Civil Investigative Demand (CID). While FTC investigations are normally...more
Publications and Advisories - February 10, 2023 – Kathleen Benway, David Keating, and Sara Pullen Guercio published “Privacy, Cyber & Data Strategy / Consumer Protection/FTC Advisory: Limit Your Health Data Sharing and Call...more
2/15/2023
/ California Consumer Privacy Act (CCPA) ,
California Privacy Rights Act (CPRA) ,
Consumer Privacy Rights ,
Cybersecurity ,
Data Breach ,
Data Privacy ,
Data Protection ,
Data Security ,
FCC ,
Federal Trade Commission (FTC) ,
Personal Information ,
Popular ,
State Privacy Laws
Artificial intelligence (AI) is expanding into more industries (often in surprising ways) and has inevitably caught the attention of federal and state regulators. Our Privacy, Cyber & Data Strategy Team summarizes the...more
12/12/2022
/ Algorithms ,
Artificial Intelligence ,
Corporate Counsel ,
Data Processors ,
Data Protection ,
Federal Trade Commission (FTC) ,
FinTech ,
Health Technology ,
Machine Learning ,
Medical Devices ,
NIST ,
Popular ,
Regulatory Oversight ,
Regulatory Standards ,
Risk Assessment ,
Technology Sector
On October 31, 2022, the Federal Trade Commission (FTC) announced it has taken action against education technology provider Chegg Inc. (“Chegg”) for its “careless” cybersecurity practices that exposed sensitive personal...more
On October 24, 2022, the Federal Trade Commission (“FTC”) announced a proposed consent order against both Drizly LLC, an online marketplace for alcohol delivery, and its CEO over the company’s alleged security failures that...more
Our Privacy, Cyber & Data Strategy and White Collar, Government & Internal Investigations teams offer key takeaways that companies should consider in the wake of the Justice Department’s first prosecution of a corporate...more
Enhancing data security programs to protect personal information is a critical area companies cannot ignore. Our Privacy, Cyber & Data Strategy and Financial Services & Products groups unpack the latest moves by the Consumer...more
Selected Developments in U.S. Law - SEC Proposed Rule Will Require Private Funds to Report Certain Cyber Events On January 26, 2022, the U.S. Securities and Exchange Commission (SEC) proposed new rules to enhance hedge fund...more
2/9/2022
/ China ,
Cyber Incident Reporting ,
Cybersecurity ,
Cybersecurity Information Sharing Act (CISA) ,
Data Breach ,
Data Privacy ,
Data Security ,
Data Subject Access Requests ,
Federal Trade Commission (FTC) ,
General Data Protection Regulation (GDPR) ,
International Data Transfers ,
Malware ,
Multi-Factor Authentication ,
NYDFS ,
Personal Data ,
Popular ,
Ransomware ,
Reporting Requirements ,
Russia ,
Ukraine
As companies scramble to address the newly exploited, ubiquitous Log4j vulnerability, companies’ actions are now the potential source for government scrutiny. Our Privacy, Cyber & Data Security Team summarizes what the Log4j...more
As an update to prior coverage of the FTC’s final revisions to the Gramm-Leach-Bliley Safeguards Rule (Final Rule), following its publication in the Federal Register on December 9, 2021, the Final Rule now will take effect on...more
On October 27, 2021, the FTC released its much-anticipated final revisions to the Gramm-Leach-Bliley Safeguards Rule (Safeguards Rule or Final Rule), following a 3-2 vote along party lines and also released a notice of...more
Selected Developments in U.S. Law -
NIST Publishes Privacy Framework Version 1.0 -
On January 16, 2020, the National Institute of Standards and Technology (NIST) published Version 1.0 of its Privacy Framework: A Tool for...more
Those who track newsworthy data breaches and other cybersecurity incidents know what type of fallout to expect from these events. Class action lawsuits from consumers, shareholders and financial institutions are now not an...more