News & Analysis as of

National Security Sensitive Personal Information Executive Orders

McDermott Will & Emery

New US Data Security Program limits sensitive data transfers

The United States Data Security Program (DSP) represents a significant regulatory undertaking by the US government to control the flow of bulk sensitive data to specific foreign countries, for national security purposes....more

Holland & Knight LLP

U.S. Health Data Affected by New National Security Restrictions on International Data Transfers

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Health Insurance Portability and Accountability Act (HIPAA)-covered entities and business associates should be familiar with restrictions on the use or disclosure of protected health information (PHI) under HIPAA rules....more

Eversheds Sutherland (US) LLP

Navigating new compliance requirements for DOJ’s Bulk Data Rule

While the US federal government is largely scaling back its rulemaking and compliance efforts, one critical exception is where personal data and technology intersect with national security. Exemplifying this trend, on April...more

ArentFox Schiff

Navigating the DOJ’s New Data Transfer Rule: Implications and Compliance Requirements

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On January 8, the US Department of Justice (DOJ) issued a final rule under Executive Order 14117, which established the Rule Preventing Access to US Sensitive Personal Data and Government-Related Data by Countries of Concern...more

Womble Bond Dickinson

DOJ’s Data Security Program Final Rules Effective - Implications for Telecom Providers

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On January 8, 2025, the U.S. Department of Justice (DOJ) issued its final rule to implement Executive Order 14117 aimed at preventing access to Americans' bulk sensitive personal data and government-related data by countries...more

Pillsbury Winthrop Shaw Pittman LLP

DOJ Releases Its Data Security Program Compliance Guide

The guide outlines the requirements of a newly implemented Data Security Program designed to prevent China, Russia and other foreign adversaries designated by the U.S. Department of Justice from accessing American’s sensitive...more

Clark Hill PLC

DOJ implements new rule restricting bulk transfers of sensitive personal data

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On April 22, FTC Commissioner Melissa Holyoak delivered the opening keynote at the IAPP Global Summit, where she emphasized the importance of vigorously enforcing privacy laws while warning against stretching the FTC’s...more

Kelley Drye & Warren LLP

The Bulk Data Access Rule: What Advertisers Need to Know

On April 11, the Department of Justice issued an extensive set of FAQs on its Bulk Data Access Rule and advised that it ​“will not prioritize civil enforcement actions against any person for violations” of the Rule through...more

WilmerHale

DOJ Issues Guidance for New Data Security Program

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On April 8, the Department of Justice’s (“DOJ’s”) final rule on Preventing Access to US Sensitive Personal Data and Government-Related Data by Countries of Concern or Covered Persons (the “Rule”) formally took effect. ...more

The Volkov Law Group

DOJ Issues Data Security Program Requirements (Part I of II)

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Many “good government” initiatives continue to be enacted or implemented on Capitol Hill or in the Executive Branch — notwithstanding changes in political control. While working on Capitol Hill, the bulk of the legislative...more

Womble Bond Dickinson

Navigating the New DOJ Data Security Program Compliance

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On January 8, 2025, the U.S. Department of Justice (“DOJ”) issued its final rule to implement Executive Order 14117 aimed at preventing access to Americans' bulk sensitive personal data and government-related data by...more

Ropes & Gray LLP

DOJ Bulk Data Final Rule Update

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Today, the Department of Justice’s (“DOJ”) Final Rule implementing former President Biden’s Executive Order 14117, “Preventing Access to Americans’ Bulk Sensitive Personal Data and United States Government-Related Data by...more

Miller Canfield

DOJ Rule Restricting Sensitive Data Transfers Takes Effect

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Today, April 8, 2025, the U.S. Department of Justice’s Final Rule restricting transfers of bulk sensitive personal data and U.S. government-related data becomes effective, implementing former President Biden’s Executive Order...more

Wiley Rein LLP

Update: DOJ and CISA Issue New National Security Program to Regulate Foreign Access to Sensitive Data

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On January 8, 2025, the U.S. Department of Justice (Department or DOJ) issued new rules required by then-President Biden’s February 2024 Executive Order (EO) 14117 to establish a new regulatory framework aimed at “Preventing...more

White & Case LLP

DOJ Issues Final Rule Prohibiting and Restricting Transfers of Bulk Sensitive Personal Data

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The Department of Justice (DOJ) issued a final rule (the "Rule") on December 27, 2024, implementing Executive Order 14117 "Preventing Access to Americans' Bulk Sensitive Personal Data and United States Government-Related Data...more

Akin Gump Strauss Hauer & Feld LLP

Security Requirements and Compliance Obligations in DOJ's Final Rule on Data Transactions

The Department of Justice’s (DOJ) final rule implements President Biden’s Executive Order 14117 of February 28, 2024, on “Preventing Access to Americans’ Bulk Sensitive Personal Data and United States Government-Related Data...more

Akin Gump Strauss Hauer & Feld LLP

DOJ Regulations Will Restrict Data Transactions to Address National Security Concerns

The Department of Justice’s (DOJ) final rule implements President Biden’s Executive Order 14117 of February 28, 2024, on “Preventing Access to Americans’ Bulk Sensitive Personal Data and United States Government-Related Data...more

Arnall Golden Gregory LLP

Access to U.S. Sensitive Personal Information and Government Related Data by Countries of Concern or Covered Persons Subject to...

The Department of Justice (“DOJ”) published its final regulations on “Preventing Access to U.S. Sensitive Personal Data and Government-Related Data by Countries of Concern or Covered Persons” (the “Final Rule”). The Final...more

Robinson+Cole Data Privacy + Security Insider

After Supreme Court Upholds Ban, Trump Issues EO Giving TikTok an Extension

Despite bipartisan support for banning TikTok – essentially spyware presenting a national security threat from the People’s Republic of China (PRC) – in the United States (as done by India) and the Supreme Court’s upholding...more

Dorsey & Whitney LLP

Justice Issues Final Rule Restricting Transfer of Personal U.S. Data to Countries of Concern, Effective in April 2025

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The U.S. Department of Justice (“DOJ”) published its final rule (“Final Rule”) on January 8, 2025, that will prohibit or restrict transfer of certain data of U.S. persons to countries of concern, including to China. The Final...more

Ropes & Gray LLP

DOJ Issues Final Rule Restricting Flow of Bulk Sensitive Personal Data to China and Other Countries of Concern

Ropes & Gray LLP on

On January 8, 2025, the Department of Justice (“DOJ”) published its Final Rule to implement President Biden’s Executive Order 14117, “Preventing Access to Americans’ Bulk Sensitive Personal Data and United States...more

King & Spalding

DOJ Issues Final Rule Restricting Foreign Access to U.S. Data

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The rule imposes substantial new diligence, reporting, cybersecurity, and auditing obligations on companies. On December 27, 2024, the U.S. Department of Justice (“DOJ”) issued a final rule implementing Executive Order...more

Davis Wright Tremaine LLP

DOJ Issues Final Rule Targeting Foreign Access to Americans’ Sensitive Data

The U.S. Department of Justice (DOJ) has issued a comprehensive final rule (the "Rule") targeting foreign access to sensitive U.S. data, including Americans' "bulk" sensitive personal data....more

WilmerHale

DOJ Issues NPRM Regarding Sensitive Data Transfers

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With the publication of a recent Notice of Proposed Rulemaking (NPRM), the Department of Justice National Security Division will soon become an important new regulator of transactions involving the transfer of sensitive U.S....more

Akin Gump Strauss Hauer & Feld LLP

Protecting Americans’ Data from Foreign Adversaries Act of 2024

On April 24, 2024, President Biden signed into law H.R. 815, a national security and foreign aid package which includes the “Protecting Americans’ Data from Foreign Adversaries Act of 2024” (“PADFA”). The Act establishes new...more

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