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Making the Connection - What Do Recent SEC Enforcement Actions Mean for Cyber Controls?

On July 18, 2024, the U.S. District Court for the Southern District of New York dismissed most of the claims brought by the Securities and Exchange Commission (the “Commission”) against SolarWinds Corp. and its Chief...more

SEC Charges SolarWinds and CISO with Fraud and Internal Controls Failures

On October 30, 2023, the Securities and Exchange Commission (“SEC”), filed a complaint against SolarWinds Corp. (“SolarWinds” or the “Company”) for fraud and internal and disclosure controls failures relating to allegedly...more

CPPA Holds Meeting to Discuss Regulations for Automated Decision-Making Technology, Cybersecurity Audits, and Cybersecurity Risk...

On July 14, the California Privacy Protection Agency (CPPA or the “Board”) hosted a meeting to discuss key issues. Notably, the Board’s New CPRA Rules Subcommittee (“the Subcommittee”) previewed three areas of forthcoming...more

Certification Under the EU-U.S. Data Privacy Framework

On July 10, 2023, the European Commission adopted an adequacy decision for the new EU-U.S. Data Privacy Framework (“EU-U.S. DPF”), the successor to the EU-U.S. Privacy Shield, which the Court of Justice of the European Union...more

Texas Set to Become the Tenth State with a Comprehensive Privacy Law

On May 28, 2023, the Texas legislature reached an agreement (by conference committee) on the Texas Data Privacy and Security Act (the Act), setting the stage for Texas to become the tenth state with a comprehensive privacy...more

White House Announces Initiatives to Promote “Responsible” AI Innovation

In light of the rapid emergence and adoption of artificial intelligence (AI) tools and systems, the Biden Administration convened the CEOs of leading AI companies on May 4, 2023 at the White House and announced several...more

Update on the EU-US Data Privacy Framework

On October 7, 2022, President Biden signed an Executive Order (“EO”) implementing the new trans-Atlantic EU-U.S. Data Privacy Framework (“EU-U.S. DPF”). The EU-U.S. DPF, previously announced by President Biden and the...more

Colorado Attorney General’s Office Publishes Proposed Rules for Colorado Privacy Act

On September 30, the Colorado Attorney General’s Office (“Colorado AG’s Office”) released proposed rules (the “Proposed Rules”) for the Colorado Privacy Act (CPA), which goes into effect on July 1, 2023. The Proposed Rules...more

FTC Issues New Dark Pattern Guidance

On September 15, 2022, the Federal Trade Commission (FTC) released a report on dark patterns (the, “Report”) that identifies the types of misleading and manipulative interface practices that the agency believes can harm...more

CFPB Targets Consumer Report Protections with an Advisory Opinion

On July 7, 2022, the Consumer Financial Protection Bureau (“CFPB”) issued an advisory opinion, “Permissible Purposes for Furnishing, Using, and Obtaining Consumer Reports” (the “Opinion”) to outline certain privacy...more

FTC Issues Long-Awaited Privacy-Focused Advance Notice of Proposed Rulemaking

On August 11, 2022, the Federal Trade Commission (the FTC or the Commission) published an Advance Notice of Proposed Rulemaking (ANPR) to request public comment on the prevalence of “commercial surveillance and data security...more

California Privacy Protection Agency Holds Special Meeting to Discuss the ADPPA

On July 28, 2022, the California Privacy Protection Agency (the “Agency”) held a special meeting (the “Meeting”) to discuss and act on the proposed federal privacy legislation, the American Data Protection and Privacy Act...more

Aerojet Rocketdyne Agrees to Pay $9 Million to Resolve False Claims Act Allegations of Cybersecurity Violations in Federal...

On July 8, 2022, the Department of Justice (“DOJ”) announced in a press release that Aerojet Rocketdyne Inc, a provider of advanced propulsion and energetics systems for multiple government agencies, reached a settlement...more

Bill Proposed in Congress to Expand Privacy Obligations of Financial Institutions

On June 23, 2022, Congressman Patrick McHenry (NC-10), released a discussion draft  (“Discussion Draft”) of new legislation set to amend the Gramm-Leach-Bliley Act (GLBA) with the intent to “modernize GLBA to better align...more

Congress Proposes Legislation Aimed at Data Brokers and Health Information

On June 15, 2022, Senator Elizabeth Warren introduced Senate Bill S.4408, Health and Location Data Privacy Act of 2022 (the “Bill”). The Bill, co-sponsored with Senators Ron Wyden, Patty Murray, Sheldon Whitehouse, and Bernie...more

Select Highlights from the California Privacy Protection Agency’s June 8 Board Meeting and Initial Statement of Reasons for CPRA...

As a follow-up to their release of draft regulations (“Draft Regulations”) for the California Privacy Rights Act (CPRA) (which we covered in this article), the California Privacy Protection Agency (“Agency”) released an...more

Key Highlights of the California Privacy Rights Act Draft Regulations

The California Privacy Protection Agency (CPPA) recently released draft regulations for the California Privacy Rights Act (CPRA) (Draft Regulations). These Draft Regulations come roughly two months before the agency is...more

California Privacy Protection Agency Releases Draft CPRA Regulations

On May 27, 2022, the California Privacy Protection Agency (CPPA) released draft regulations for the California Privacy Rights Act (CPRA) (Draft Regulations). The Draft Regulations come roughly two months before the agency is...more

FTC Votes Affirmatively on COPPA Compliance for Education Technology and on Seeking Public Comment for Endorsement Guides

On May 19, 2022, the Federal Trade Commission (FTC or the “Commission”) including Commissioner Alvaro M. Bedoya in his first sitting since being sworn in to the Commission, held an open meeting to discuss two critical topics:...more

CISR Proposes Teenage Privacy Program Initiative

On April 19, 2022, the Better Business Bureau’s (BBB) Center for Industry Self-Regulation introduced the TeenAge Privacy Program (TAPP), an emerging initiative that sets out to help companies develop a teen-centric approach...more

Introducing the CBPR - A New Development in Cross Border Data Flows

On April 21, 2022, the U.S. Department of Commerce Secretary Gina Raimondo (the “Department”) announced a key development in international collaboration concerning cross-border data flows with the newly created Global...more

Colorado Privacy Update - Pre-Rulemaking Considerations

Colorado, as the third U.S. state to adopt a comprehensive privacy law, is making significant strides in its rule-making activities. On April 12, 2022, the Colorado Attorney General’s Office issued prepared remarks from...more

California Privacy Protection Agency Board Conducts Pre-Rulemaking Sessions

On March 29 and March 30, 2022, the Board of the California Privacy Protection Agency (CPPA or “Agency”) conducted informational sessions on the California Privacy Rights Act (CPRA) and allowed public comment on its...more

Sri Lanka Becomes the First South Asian Country To Pass Comprehensive Privacy Legislation

On March 18th, 2022, Sri Lanka enacted the Personal Data Protection Act, No. 9 of 2022 (the “Act” or “PDPA”) thereby becoming the first South Asian country to enact comprehensive data protection legislation. The law is...more

California Office of the Attorney General Clarifies What Constitutes an “Inference” under the CCPA

In the first of its kind “opinion” from the California Office of the Attorney General (“OAG”), the agency addressed the question of whether a consumer’s “right to know” what personal information a business holds about the...more

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