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Eye on Privacy: 2023 Year in Review

ARTIFICIAL INTELLIGENCE - What is the Privacy Impact of the White House AI Order for Businesses? Posted November 28, 2023 Biden’s sweeping AI Executive Order sought to have artificial intelligence used in accordance...more

FTC Reaches $7 Million Settlement Over Response Tree’s “Consent Farm” Sites

Continuing its focus on potential dark patterns, the FTC has reached a settlement with the lead generation company Response Tree LLC and its president over allegations that the company ran sites that tricked people into...more

Connected Devices: Eyes on EU Data Act

The European Council recently approved a final version of the EU Data Act. The Act applies to manufacturers of connected devices. Among other things, it gives consumers certain rights about the information those devices...more

What Is the Privacy Impact of the White House AI Order for Businesses?

Biden’s sweeping AI Executive Order sought to have artificial intelligence used in accordance with eight underlying principles. The order, while directed to government agencies, will impact businesses as well. In particular,...more

Amended Kochava Complaint Gives Insight into FTC’s View of Harm from Data Profiles

The FTC’s second attempt to pursue the data broker, Kochava, continues to move forward. The amended complaint, which was just unsealed and thus available for the public to review, gives insight into the agency’s perspective...more

The Comprehensive Privacy Law Deluge: Impact on Loyalty Programs

Among the various requirements under US state comprehensive privacy laws, those that relate to loyalty programs may be some of the most confusing. Only three states — California, Colorado and Florida — regulate these...more

OpenAI – FTC Opens an Investigation

As many who are keeping track of generative AI developments are aware, the FTC recently announced that it is investigating OpenAI’s ChatGPT product. For the privacy practitioner this investigation is important given that...more

California Regulator Drives Inquiry into Vehicle Data

The enforcement division of the California Privacy Protection Agency (CPPA) recently announced it intends to review the privacy practices of connected vehicles. The driving force behind the review is the technologies in...more

State Comprehensive Privacy Laws – Beaver State Makes a Dozen

Oregon’s governor has now signed into law the state’s comprehensive privacy law. Meaning, there are now 12 states with these laws, six of which were passed just this year (others passed in 2023 were Iowa, Indiana, Tennessee,...more

Impact of the Last Minute CCPA-Enforcement Delay

A California court recently issued a ruling delaying the CPPA’s ability to enforce the most recent CCPA regulations until March 29, 2024. This does not delay enforcement of the CCPA statute or existing regulations....more

The Comprehensive Privacy Law Deluge: Approaching Notice Obligations

When thinking about privacy notice obligations, companies often -incorrectly- leap to the wording in their privacy policies. The new comprehensive state privacy laws are a reminder that notice obligations are a bit broader...more

The Comprehensive Privacy Law Deluge: What to Do About “Profiling”

With a little less than a week before the next US state “comprehensive” privacy laws (Colorado and Connecticut) go into effect, many are reviewing existing practices. One that keeps coming up is the concept of “profiling.” As...more

Another Governor Signs: Florida Privacy Law Will be Effective July 2024

Florida has become the latest state to enact a comprehensive privacy law this year when SB 262 was signed by Governor DeSantis last week. It combines some new, and some familiar, provisions. It has also passed a child privacy...more

Montana Governor Signs Big Sky’s Privacy Law

Montana now joins a growing list of states to have a comprehensive privacy law. The law was signed by the governor on May 19, 2023 and will go into effect October 24, 2024. This is before some Iowa (effective January 1, 2025)...more

Another Governor Signs: Tennessee Volunteers to Join the Privacy Patchwork

The Tennessee governor has signed Tennessee’s comprehensive privacy law, which as we have indicated will go into effect July 1, 2025. As initially proposed, the law would have been effective July 1, 2024, and would have...more

Preparing for the US Comprehensive Privacy Law Deluge

With January well in the rear view mirror, companies are setting their privacy compliance sights on the next two laws to come into effect on July 1, 2023: Colorado and Connecticut. Knowing, of course, that Utah (December 31,...more

Governor Signs: Hoosier State Adds to the US Privacy Patchwork

Indiana has now become the seventh US state to enact a comprehensive privacy law after Senate Bill 5 (“SB5”) was signed by the governor on May 1, 2023. The new law will go into effect January 1, 2026, and is almost identical...more

FTC Renews Focus on Dark Patterns

Following its 2021 Dark Patterns enforcement policy, the FTC recently issued a staff report on the practice. The report summarized many of the cases the agency has brought against companies it alleges have engaged in “dark...more

Preparing for US State Privacy Law Compliance: The Six Month Mark

With six months before the first of the new US state general privacy laws go into effect, there are several steps companies can take now to begin to prepare. Unfortunately there are some parts of compliance that will be...more

Connecticut Fifth State to Pass a Comprehensive Privacy Law

Connecticut just joined California, Colorado, Utah, and Virginia in passing a comprehensive privacy law. The Connecticut Data Privacy Act (CTDPA) goes into effect July 1, 2023, the same time as Colorado’s very similar law...more

The Beehive State Joins the State Privacy Law Hive: Utah Privacy Law Passes

Utah recently joined California, Colorado, and Virginia in passing a comprehensive privacy law. It goes into effect December 31, 2023 and shares similarities with other states’ laws. Businesses may be glad to learn that Utah...more

DAA Issues Warning On Device Fingerprinting

The Digital Advertising Accountability Program, which enforces privacy principles for digital advertising, issued a compliance warning to advertisers regarding device fingerprinting. This warning is worth keeping in mind,...more

Virginia Privacy Law Continues to Progress Towards 2023 Implementation

Virginia edges closer to its privacy law January 2023 implementation. A new working group report gives some insight on implementation focus. The working group is tasked with giving advice on implementing the Virginia Consumer...more

Australia Objects to 7-Eleven’s In-Store Use of Facial Recognition Technology

The Office of the Australian Information Commissioner issued a determination earlier this fall about 7-Eleven’s use of “faceprints.” The OAIC found the convenience store improperly collected faceprint information without...more

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