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European Commission Publishes Long-Awaited New Standard Contractual Clauses

Today, the European Commission published finalized versions of new Standard Contractual Clauses (SCCs). The Commission has published two sets of clauses....more

The GDPR Reaches the US Supreme Court in Cert Petition

The EU’s General Data Protection Regulation (GDPR) has been raised in a petition for certiorari before the US Supreme Court, apparently for the first time since the GDPR entered into application in 2018. A party in Vesuvius...more

California Department of Justice Releases Post-Finalization Modifications to CCPA Regulations

On October 12, 2020, the California Department of Justice (“Department”) released its first set of proposed post-finalization modifications to the California Consumer Privacy Act Regulations (the “CCPA Regulations”)....more

New Privacy Browser Extension Released under CCPA Global Do Not Sell Rules

On October 7, 2020, an organization named Global Privacy Control (“GPC”) issued a press release announcing an initiative to make a new “global privacy control” available to consumers as contemplated by the CCPA Regulations. ...more

California Mandates COVID Exposure and Outbreak Reporting to Employees, Government Agencies

On Thursday, September 17, 2020, California Governor Gavin Newsom signed Assembly Bill 685 (“AB685”) into law. AB685 amends a number of portions of California’s Labor Code to address the COVID-19 pandemic....more

German DPA Publishes Schrems II Transfer Compliance Checklist and Suggested Modifications to SCCs

On August 24, 2020, the data protection authority of the German state of Baden-Württemberg (the “DPA”) published guidance (the “Guidance”) on international transfers of personal data following the Schrems II judgment....more

Final CCPA Regulations Approved, Effective Immediately

On Friday, August 14, 2020, the California Office of Administrative Law (OAL) approved the California Office of the Attorney General’s (OAG) Final CCPA Regulations (the “Regulations”) and filed them with California Secretary...more

EDPB to Publish FAQs on Data Transfers

This morning, Germany’s Federal Data Protection Authority (DPA) announced that the European Data Protection Board (EDPB) has finalized an initial set of FAQs on international transfers in light of the recent Schrems II...more

EU DPAs Announce Post-Schrems Enforcement Plans

The European Court of Justice (ECJ) issued its much-anticipated decision in the Schrems II case.  As we analyze in detail in an earlier blog post, the ECJ’s decision invalidates Privacy Shield while leaving Standard...more

California Privacy Rights Act (CPRA) Will be on November Ballot

The California Secretary of State has announced that the California Privacy Rights Act (CPRA) will be on California’s November 3, 2020 ballot. ...more

California AG Publishes Final CCPA Regulations, Seeks Possible July 1 Effective Date

Since the California Consumer Privacy Act (CCPA) entered into force on January 1, 2020, many companies have been closely following the development of CCPA Regulations by the California Attorney General’s Office (AG’s Office)....more

A CCPA Private Right of Action on the Horizon: Class Action Complaints Test Whether Plaintiffs Can Sue for Any Violation of the...

Plaintiffs’ counsel have started to lay the groundwork for a broad private right of action under the California Consumer Privacy Act (CCPA). The first part of this article provides an overview of how the CCPA addresses...more

BREAKING: Location and Mobile Data in the Fight against COVID-19 – An Overview of U.S. and Global Efforts

Governments are increasingly seeking to leverage consumer geolocation and other mobile device data to assist with fighting the spread of COVID-19, as cases continue to mount globally. Location data can be of significant...more

BREAKING: Leveraging Location Data to Fight COVID-19 – How the U.S. Compares to the Rest of the World

Governments are increasingly seeking to leverage consumer geolocation data collected by industry as a tool to assist with fighting the spread of COVID-19....more

California Attorney General Issues Second Round of Modifications to CCPA Regulations

At approximately 6:00 p.m. today, March 11, 2020, California Attorney General Xavier Becerra announced a second round of modifications to the draft regulations his office is preparing for the California Consumer Privacy Act...more

The Updated CCPA Regulations: 30 Potentially Material Business Impacts

California Attorney General Xavier Becerra has released updated regulations to the California Consumer Privacy Act (CCPA) that contain a number of material modifications to the initial CCPA regulations released in October...more

The Draft CCPA Regulations: 21 Potentially Significant Business Impacts

Our Privacy & Data Security Team summarizes the portions of California’s proposed regulations for the California Consumer Privacy Act (CCPA) that are likely of material interest to companies across industries and highlights...more

FashionID: Another Big ECJ Facebook Case with Implications for the Entire Ad-Supported Internet

On July 29, 2019, the European Court of Justice (“ECJ”) issued its decision in the case of FashionID GmbH & Co. KG v. Verbraucherzentrale NRW.  The ECJ found that websites that integrate Facebook plugins are jointly...more

CCPA Carve-Out for Online Advertising? Proposed Amendment Exempts Certain Advertising Data from Do-Not-Sell Restrictions

California passed the California Consumer Privacy Act (CCPA) in September 2018, and the CCPA enters into force on January 1, 2020. One of the CCPA’s core elements is a right for consumers to know when a company is selling...more

Google-Style GDPR Fines for Everyone? Bavarian DPA Conducts Website Cookie Practices Sweep, Announces Fines under Consideration

As has been widely reported, in late January the French privacy supervisor CNIL fined Google €50 million for privacy violations relating to targeted marketing using Android user data. One of the core violations the CNIL...more

German DPA Announces GDPR Compliance Survey of Large Companies – Translation Provided

Following a two-year grace period, EU General Data Protection Regulation (GDPR) entered into force on May 25, 2018. For many companies, preparing for the GDPR was a multi-year project involving multiple teams and input or...more

German DPAs Issue DPIA Blacklists; Many Companies Likely to be Affected

The GDPR entered into force on May 25, 2018. One of the GDPR’s core going-forward obligations is the duty to conduct Data Protection Impact Assessments (DPIAs) over processing activities that create a “high risk” to...more

On GDPR Day, Austrian DPA issues First Binding DPIA Whitelist

The GDPR entered into force on May 25, 2018. One of the GDPR’s core going-forward obligations is the duty to conduct Data Protection Impact Assessments (DPIAs) over processing activities that create a “high risk” to...more

Belgian Court Uses Novel Argument to Assume International Jurisdiction over Non-EU Facebook Entities

On February 16, 2018, the Brussels Court of First Instance rendered a judgment in proceedings brought by the Belgian Privacy Commission’s against Facebook. The case forms one part of two-tiered litigation brought by the...more

German DPAs Publish Model GDPR Processing Records – Translations Provided

In just under 100 days, the EU General Data Protection Regulation (GDPR) enters into force. One of the major changes the GDPR introduces is a duty for in-scope controllers and processors to maintain written records of their...more

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