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Biden Issues Executive Order Redirecting and Clarifying Scrutiny of Chinese Apps

Key Points - On June 9, President Biden signed an executive order (“EO”) revoking a series of Trump-era EOs targeting specific Chinese “connected software applications” (“apps”), including TikTok and WeChat. The EO calls...more

Second Circuit Weighs in on Article III Standing in Data Breach Lawsuits, Denying Existence of a Circuit Split

While some states have enacted privacy laws granting consumers the right to bring a private right of action in a data breach context, federal courts have struggled to fit data breach injury into traditional Article III...more

Department of Labor’s Cybersecurity Guidance for Benefit Plans Signals Increased Scrutiny

On April 14, 2021, the Department of Labor (DOL) issued its first set of guidance documents related to the cybersecurity of retirement benefit plans covered by the Employee Retirement Income Security Act (ERISA). The...more

New Proposed EU AI Regulation Extends Beyond Europe

On April 21, 2021, the European Commission (Commission) published its draft Regulation on Artificial Intelligence (AI). It follows the strategies outlined in the February 2020 Commission’s White Paper on AI. The draft...more

FDA Appoints Acting Director of Medical Device Security, Signaling Increased Commitment to Medical Device Cybersecurity

The U.S. Food and Drug Administration (FDA) announced that the newly-created post of Acting Director of Medical Device Security has been filled by Kevin Fu, a University of Michigan associate professor and founder of the...more

Update: Protecting Privilege: Top 10 Checklist for Cybersecurity Forensic Investigation Reports

In ongoing multidistrict litigation concerning Capital One’s 2019 data breach, Capital One succeeded in defeating a motion to compel disclosure of a privileged root cause analysis conducted by PwC. In contrast to an earlier...more

President Trump Signs IoT Cybersecurity Measure into Law

On Friday, December 4, 2020, President Donald Trump signed H.R. 1668, the Internet of Things (IoT) Cybersecurity Improvement Act of 2020, into law. The measure, which was approved by the House of Representatives in September...more

Abu Dhabi Global Market Launches Public Consultation on New Data Protection Regulatory Framework

On November 19, 2020, the Abu Dhabi Global Market (ADGM), a financial free-zone in the United Arab Emirates (UAE), announced the issuance of a public consultation paper on its proposed new Data Protection Regulations 2020...more

Congress Sends IoT Cybersecurity Measure to President Trump’s Desk

On Tuesday, November 17, the Senate passed H.R. 1668, the Internet of Things (IoT) Cybersecurity Improvement Act of 2020, by unanimous consent. The bill, which previously passed the House of Representatives in September after...more

Massachusetts Voters Approve Vehicle Data Access Initiative

Voters in Massachusetts overwhelmingly approved a ballot initiative that gives independent mechanics greater access to vehicle data, a move that vehicle manufacturers have foreshadowed could have significant cyber and privacy...more

CPRA Rivals GDPR’s Privacy Protections While Emphasizing Consumer Choice

The newly passed Proposition 24, the California Privacy Rights Act (CPRA), represents the second time in two years that California has instituted a comprehensive privacy statute that fundamentally changes data privacy...more

New DIFC Data Protection Law in Force - What You Need to Know

On October 1, 2020, the three-month grace period for businesses to comply with the Dubai International Financial Centre (DIFC) Data Protection Law (DIFC Law No. 5 of 2020) (“DPL 2020”) came to an end. Regulating the...more

Protecting Privilege: Top 10 Checklist for Cybersecurity Forensic Investigation Reports

- In ongoing multidistrict litigation concerning Capital One’s 2019 data breach, Capital One succeeded in defeating a motion to compel disclosure of a privileged root cause analysis conducted by PwC. - In contrast to an...more

New Privacy Division Created by Massachusetts Attorney General

Massachusetts Attorney General (AG) Maura Healey announced the creation of a Data Privacy and Security Division, focusing on protecting consumers from privacy and security breaches and threats. AG Healey named Sara Cable as...more

Vermont Attorney General Provides Guidance on Security Breach Notice Act

On March 5, 2020, Gov. Phil Scott (VT-R) signed into law amendments to the Security Breach Notice Act (the “Act”). The amendments, which originated in the State Senate as part of an initiative addressing a number of data...more

SEC’s Examination Function Warns Its Registrants of Risks Associated with Dangerous Malware

- In the age of broad corporate teleworking brought on by COVID-19, OCIE of the SEC has observed during recent examinations that investment advisers, broker-dealers and investment companies are subject to an increased threat...more

10 Things You Need to Know About the EU White Paper on Artificial Intelligence

On February 19, 2020, the European Commission (Commission) published proposals for the regulation of Artificial Intelligence (AI) with potentially far-reaching implications both for users and developers worldwide. The...more

New AV 4.0 Guidance on US Government Involvement in Autonomous Vehicle Policy Provides Cross-Agency Map of Federal AV Efforts

Key Points - AV 4.0 provides a unified overview of the U.S. government’s involvement in AV policy and development. It shifts federal AV guidance toward a multi-agency, coordinated effort led by the White House. - The new...more

New Autonomous Vehicle Legislation Proposed—What You Should Know

• In October, the House Energy and Commerce Committee and the Senate Commerce, Science and Transportation Committee unveiled a partial discussion draft of autonomous vehicle (AV) legislation. The draft text addresses safety...more

Issues to Consider when Evaluating Cyber Coverage in Light of the CCPA and Other State Privacy Laws

With the expansion of privacy legislation—from the General Data Protection Regulation (GDPR) in Europe to the coming California Consumer Privacy Act (CCPA) in the United States—cyber liability insurance is taking on increased...more

Summary of FTC COPPA Workshop – Key Issues and Takeaways

On October 7, the Federal Trade Commission (FTC or the “Commission”) brought together privacy and technology stakeholders for a public workshop aimed at informing updates to regulations promulgated under the Children’s Online...more

Continuing GDPR Pressure for Adtech

Data protection authorities (DPAs) in the European Union (EU) continue to scrutinize practices in the adtech sector for compliance with the EU’s General Data Protection Regulation (GDPR) and local data protection and...more

New York Enacts SHIELD Act with Expansive Data Breach Notification and Data Security Requirements

• New York recently enacted the Stop Hacks and Improve Electronic Data Security (SHIELD) Act, which expands data breach notification requirements and imposes new data security obligations on businesses that own, license or,...more

A Year of GDPR: Five Recommendations to Help Limit Regulatory Scrutiny

A year ago, on May 25, 2018, the European Union’s General Data Protection Regulation (GDPR) came into force. With its extraterritorial scope and detailed requirements, the GDPR aimed to change the approach to personal data...more

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