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Ring, Ring, it’s the FCC Calling- TracFone to Pay $16M to Settle FCC Investigation

TracFone, the pre-paid phone company, recently settled with the FCC over allegations that the company failed to protect customer information during three different data incidents. According to the FCC, in each of the...more

We Don’t Use Dark Patterns!? FTC and Consumer Protection Networks Review Suggests You Might

In its ongoing concern with “dark patterns,” the FTC recently announced results of two reviews of sites and apps purportedly engaging in the practice. As a reminder, the FTC views as “dark patterns” practices or web designs...more

The Land of 10,000 Lakes Adds New Consumer Privacy Law: Minnesota Joins Privacy Fray

Minnesota’s governor has now signed into law that state’s comprehensive privacy law. For those keeping count – that is number 19 of state “comprehensive” privacy laws, with six in 2024 alone. The Minnesota law will go into...more

Mid-Year Recap: Think Beyond US State Laws!

Much of the focus on US privacy has been US state laws, and the potential of a federal privacy law. This focus can lead one to forget, however, that US privacy and data security law follows a patchwork approach both at a...more

Maryland, the Old Line State, Creates New Lines with Consumer Privacy Law

Maryland’s new comprehensive data privacy law, the Maryland Online Data Privacy Act, was recently signed into law by Governor Moore. This brings the total number of state “comprehensive” privacy laws to 18, five of which have...more

Nebraska Fourth State to Enact Privacy Law in 2024

Nebraska’s governor has now signed into law the state’s “comprehensive” privacy law making it the fourth one this year, and the 17th overall. It will take effect on January 1, 2025 – the same day as Delaware, Iowa, and New...more

Utah Breach Notice Law Amended, Effective May 1

Utah, among other privacy laws it has enacted or modified recently, has also modified its breach notification law. This follows last year’s changes to the law, which among other things codified the state’s Cyber Center....more

Kentucky’s New Consumer Privacy Law: Is the Privacy Grass Greener in the Bluegrass State?

With the Kentucky governor recently signing into law that state’s privacy law the US now has 16 states with “comprehensive” privacy laws. This newest one will go into effect on January 1, 2026 – the same day as Indiana. It...more

New Hampshire, the Granite State, Joins Privacy Law Deluge: Sets Its Law in Stone

New Hampshire’s governor has signed into law the second state comprehensive privacy law of 2024. The law takes effect on January 1, 2025 – the same day as Iowa and Delaware (with New Jersey going into effect two weeks later)....more

EDPB Provides Guidance on Determining Primary Supervisory Authority

This month the EDPB shed light on the question of lead supervisory authorities. The issue arose in response to a question late last month from the French supervisory authority. Some background. As most international...more

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

The Garden State Cultivates a Consumer Privacy Law – The First for 2024

New Jersey’s governor has signed into law the first US state comprehensive privacy law of 2024. It will go into effect January 16, 2025. For those keeping score, that puts New Jersey after Florida, Oregon, Texas (all July 1,...more

Current Status of US State Privacy Law Deluge: It’s 2024, Do You Know Where Your Privacy Program’s At?

As we begin the new year, many are wondering whether the growing list of US state privacy laws apply to them, and if so, what steps they should take to address them. For companies that gather information from consumers,...more

Data Broker Rulemaking in Texas and Oregon

Both Texas and Oregon recently adopted rules that will, among other things, implement a registry required by both states’ data broker laws. The Texas law went into effect September 1, 2023, and the Oregon law will go into...more

FTC Decision with Global Tel*Link Signals Expectations for Use of Testing Environments

The FTC recently announced a settlement with Global Tel*Link, a telecommunications company that contracts with prisons and jails to provide communication services to incarcerated individuals and their families. Those who use...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

CNIL Fines Canal+ Over Marketing and Data Security Concerns

The French Data Protection Authority announced a €600,000 fine against Groupe Canal+ over concerns with the media company’s direct marketing activities. According to the CNIL, the company sent users email marketing without...more

No Need to Mind the Gap – UK Extension is a Data Bridge for US-UK Data Transfers

Beginning today, the UK adequacy decision for US data protection measures goes into effect. As a result, UK companies can transfer personal information to entities in the US that are participants in the EU-US Data Privacy...more

The “First State” Officially Becomes the Thirteenth State with a Comprehensive Data Privacy Law

After some delay, Delaware’s governor has at last signed into law the thirteenth state comprehensive privacy law. This is the seventh law passed in 2023, joining Iowa, Indiana, Tennessee, Montana, Florida, and Oregon. The law...more

In 2024 Oregon Will Join Short List of States Requiring Data Broker Registration

Oregon recently joined Vermont and California as the third state requiring data broker registration before collecting, selling, or licensing “brokered personal data.” Several types of entities are exempt from the law. These...more

Iowa Joins Growing List to Offer Potential Safe Harbor for Companies With Security Programs

Iowa recently became the fifth state to offer businesses a safe harbor if they have a written cybersecurity program. Others are Connecticut (October 1, 2021), Ohio (effective November 2, 2018), Oregon (effective January 1,...more

EU Adopts Adequacy Decision for EU-US Data Privacy Framework

The EU Commission adopted today an adequacy decision for the EU-US Data Privacy Framework. As we indicated last month, this has been an area closely watched by those transferring data from the EU to the US. The issue has been...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

The Lone Star State Joins the Privacy Law Deluge: Another Governor Signs

Texas has now become the 11th state, following Florida, to have a “comprehensive” privacy law. HB 4 was signed by the governor on June 18, 2023. This caps off a busy spring for state lawmakers not only in Texas, but Florida,...more

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