Four Companies Settle SEC Allegations for “Misleading Cyber Disclosures” Regarding SolarWinds -
On October 22, 2024, the Securities and Exchange Commission (“SEC”) announced settlements with four companies for alleged...more
11/8/2024
/ Artificial Intelligence ,
Consumer Financial Protection Bureau (CFPB) ,
Covered Entities ,
Cybersecurity ,
Disclosure Requirements ,
European Commission ,
Final Rules ,
Notice of Proposed Rulemaking (NOPR) ,
NYDFS ,
Public Disclosure ,
Risk Management ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act of 1934 ,
Settlement ,
Social Engineering ,
Social Networks ,
SolarWinds ,
UK
FTC Staff Report on Social Media Platforms’ Privacy and Security Practices -
On September 19, 2024, the Federal Trade Commission (“FTC” or the “Commission”) announced the release of its staff report, “A Look Behind the...more
10/11/2024
/ Algorithms ,
Artificial Intelligence ,
California ,
Data Security ,
Enforcement Actions ,
Federal Trade Commission (FTC) ,
FTC Act ,
GAO ,
Governor Newsom ,
Governor Vetoes ,
Machine Learning ,
Marketing ,
New Legislation ,
Privacy Laws ,
Settlement ,
Social Media ,
Unfair or Deceptive Trade Practices
FTC and DOJ Reach US$2.95 Million Settlement with Verkada for Alleged Violations of the FTC Act and CAN-SPAM Act -
On August 30, 2024, the Federal Trade Commission (“FTC”) announced a proposed order with Verkada Inc....more
9/27/2024
/ Amicus Briefs ,
Arbitration Agreements ,
Artificial Intelligence ,
CAN-SPAM Act ,
COPPA ,
Cyber Attacks ,
Cybersecurity ,
Department of Health and Human Services (HHS) ,
Department of Justice (DOJ) ,
Ethics ,
EU ,
European Commission ,
Facial Recognition Technology ,
Federal Trade Commission (FTC) ,
FTC Act ,
General Data Protection Regulation (GDPR) ,
Health Insurance Portability and Accountability Act (HIPAA) ,
Human Rights ,
Online Reviews ,
Securities and Exchange Commission (SEC) ,
Settlement ,
Standard Contractual Clauses ,
UK ,
Web Tracking
X Agrees to Stop Processing EU Data to Train its Grok AI -
Ireland’s Data Protection Commission (“DPC”) recently filed an urgent High Court application against X (formerly Twitter) for using the personal data of European...more
9/13/2024
/ Artificial Intelligence ,
Cybersecurity ,
Data Collection ,
Data Protection ,
Data Security ,
EU ,
EU-US Privacy Shield ,
European Data Protection Board (EDPB) ,
Fines ,
Ireland ,
Liability ,
Personal Data ,
Sensitive Personal Information ,
Twitter ,
Uber
U.S. Court Axes Most of SEC's SolarWinds Data Breach Suit -
The U.S. District Court for the Southern District of New York recently dismissed much of the U.S. Securities and Exchange Commission’s (“SEC”) suit against...more
8/2/2024
/ Artificial Intelligence ,
Audits ,
Automated Decision Systems (ADS) ,
COPPA ,
Cyber Attacks ,
Cybersecurity ,
Data Breach ,
Data Privacy ,
Dismissals ,
EU ,
EU-US Privacy Shield ,
European Economic Area (EEA) ,
Federal Trade Commission (FTC) ,
General Data Protection Regulation (GDPR) ,
Instant Messaging Apps ,
Misleading Statements ,
Regulation Technical Standards (RTS) ,
Risk Assessment ,
ROSCA ,
Securities and Exchange Commission (SEC) ,
Settlement ,
SolarWinds
SEC Fines the New York Stock Exchange’s Parent Company $10 million for Failure to Promptly Notify Its Subsidiaries of Cybersecurity Breach -
On May 22, 2024, the Securities and Exchange Commission (“SEC”) imposed a $10...more
6/14/2024
/ Annual Reports ,
Artificial Intelligence ,
Breach Notification Rule ,
Colorado ,
Cybersecurity ,
Data Breach ,
Data Collection ,
Data Protection ,
Enforcement Actions ,
Federal Trade Commission (FTC) ,
Information Commissioner's Office (ICO) ,
Machine Learning ,
New Legislation ,
NYSE ,
Popular ,
Securities and Exchange Commission (SEC) ,
UK
European Data Protection Board Publishes Strategy for 2024-27 -
The European Data Protection Board (“EDPB” - the EU body tasked with promoting consistency and cooperation in enforcement of the GDPR) has outlined its...more
5/6/2024
/ Artificial Intelligence ,
Department of Health and Human Services (HHS) ,
Draft Guidance ,
Enforcement ,
European Data Protection Board (EDPB) ,
Federal Trade Commission (FTC) ,
General Data Protection Regulation (GDPR) ,
Health Insurance Portability and Accountability Act (HIPAA) ,
HIPAA Privacy Rule ,
Machine Learning ,
Penalties ,
Personal Data ,
Reproductive Healthcare Issues ,
Transparency ,
UK
April 2024 On April 4, 2024, the U.S. Department of Homeland Security’s Cybersecurity and Infrastructure Security Agency (“CISA”) published a 447-page Notice of Proposed Rulemaking (“Proposed Rules”) in accordance with the...more
4/19/2024
/ Artificial Intelligence ,
California Consumer Privacy Act (CCPA) ,
California Privacy Protection Agency (CPPA) ,
Critical Infrastructure Sectors ,
Cyber Incident Reporting ,
Cyber Incident Reporting for Critical Infrastructure Act of 2022 (CIRCIA) ,
Cybersecurity ,
Cybersecurity Information Sharing Act (CISA) ,
Data Security ,
Enforcement Actions ,
Federal Trade Commission (FTC) ,
Government Agencies ,
Machine Learning ,
OMB ,
Online Safety for Children ,
Privacy Laws ,
Proposed Rules ,
Reporting Requirements ,
UK ,
Voluntary Compliance
European Parliament Approves EU AI Act -
On March 13, 2024, the European Parliament approved the EU Artificial Intelligence Act (“AI Act”). A first of its kind legal framework for AI, the AI Act has extraterritorial effect,...more
3/29/2024
/ Appeals ,
Artificial Intelligence ,
California Privacy Protection Agency (CPPA) ,
Consent ,
Court of Justice of the European Union (CJEU) ,
Cybersecurity Framework ,
Data Brokers ,
Data Collection ,
European Parliament ,
Federal Trade Commission (FTC) ,
Foreign Adversaries ,
General Data Protection Regulation (GDPR) ,
Popular ,
Sensitive Personal Information ,
Strategic Planning ,
Transparency
FTC Proposes New Protections to Guard Against AI Impersonations of Individuals -
Amidst growing concerns that emerging technology—including AI-generated deepfakes—threaten to increase the prevalence of impersonation fraud,...more
3/1/2024
/ Anti-Terrorism Financing ,
Artificial Intelligence ,
Cybersecurity ,
Deep Fake ,
EU ,
European Convention on Human Rights ,
Federal Trade Commission (FTC) ,
Human Rights ,
Russia ,
Securities and Exchange Commission (SEC) ,
Terms of Service
FTC Announces Proposed Settlement with Data Aggregator over its Alleged Selling of Precise Location Data -
The Federal Trade Commission (“FTC”), on January 18, 2024, announced a proposed settlement with InMarket Media...more
FTC Settles with Rite Aid on its Use of AI and Processing of Biometric Information -
The Federal Trade Commission (“FTC”), on December 19, 2023, announced that it had reached a settlement with Rite Aid Corporation (“Rite...more
1/19/2024
/ Artificial Intelligence ,
Biometric Information ,
COPPA ,
Data Brokers ,
Data Retention ,
Enforcement Actions ,
Facial Recognition Technology ,
Federal Trade Commission (FTC) ,
FTC Act ,
Inventors ,
Notice of Proposed Rulemaking (NOPR) ,
Opt-In ,
Patents ,
Rite Aid ,
Sensitive Personal Information ,
Settlement ,
UK
The Biden Administration Issues Executive Order on Artificial Intelligence -
On October 30, 2023, President Biden signed an Executive Order on Safe, Secure, and Trustworthy Artificial Intelligence (the “Order”)...more
11/17/2023
/ Artificial Intelligence ,
Biden Administration ,
Chief Information Security Officer (CISO) ,
Cyber Crimes ,
Cyber Incident Reporting ,
Cybersecurity ,
Data Breach ,
Executive Orders ,
Federal Trade Commission (FTC) ,
Financial Institutions ,
NYDFS ,
Ransomware ,
Regulatory Agenda ,
Securities and Exchange Commission (SEC) ,
SolarWinds
Proposed EU-US Data Transfer Agreement Continues to Face Obstacles in Parliament -
As we reported in Issue 29 of Cyber Bits, the European Parliament Committee on Civil Liberties, Justice and Home Affairs (the “EP...more
4/28/2023
/ Artificial Intelligence ,
Biden Administration ,
Cybersecurity ,
Data Privacy ,
Data Protection ,
EU-US Privacy Shield ,
European Commission ,
European Parliament ,
Federal Trade Commission (FTC) ,
Health Insurance Portability and Accountability Act (HIPAA) ,
International Data Transfers
SEC Division of Examinations Issues Risk Alert on Regulation S-ID and Identity Theft Prevention Programs -
On December 5, 2022, the Securities and Exchange Commission (“SEC”) Division of Examinations (“EXAMS”) issued a...more
12/16/2022
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
American Civil Liberties Union (ACLU) ,
Artificial Intelligence ,
Broker-Dealer ,
Cyber Attacks ,
Cybersecurity ,
Data Breach ,
Data Transfers ,
EDPS ,
EU ,
European Data Protection Board (EDPB) ,
European Economic Area (EEA) ,
Federal Trade Commission (FTC) ,
General Data Protection Regulation (GDPR) ,
Investment Adviser ,
Minors ,
Online Safety for Children ,
Personal Data ,
Policies and Procedures ,
Proposed Legislation ,
Regulation S-ID ,
Risk Alert ,
Securities and Exchange Commission (SEC) ,
SolarWinds
SEC Chair Gensler Indicates Commission is Looking to Update SEC’s Regulation S-P -
On September 28, 2022, Securities and Exchange Commission (“SEC” or the “Commission”) Chairman Gary Gensler appeared via video at the...more
10/14/2022
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Algorithms ,
Anti-Discrimination Policies ,
Artificial Intelligence ,
Biden Administration ,
Broker-Dealer ,
Cloud Service Providers (CSPs) ,
Cybersecurity ,
Data Breach ,
Data Privacy ,
EU ,
EU-US Privacy Shield ,
Federal Trade Commission (FTC) ,
Foreign Trade Regulations ,
Gramm-Leach-Blilely Act ,
Hackers ,
Information Commissioner's Office (ICO) ,
International Data Transfers ,
Investment Adviser ,
Investment Companies ,
Privacy Framework ,
Regulation S-P ,
Request For Information ,
Right of Access ,
Securities and Exchange Commission (SEC) ,
Subject Access Request (SAR) ,
Title V ,
U.S. Commerce Department ,
Uber ,
UK ,
UK GDPR
The U.S. and many other nations recently imposed unprecedented sanctions on Russia in response to Russia’s military action in Ukraine. More details about some of these sanctions can be found in Dechert’s related OnPoint...more
3/11/2022
/ Artificial Intelligence ,
Biometric Information ,
Cyber Attacks ,
Cybersecurity ,
Data Collection ,
Data Privacy ,
Data Protection ,
European Data Protection Board (EDPB) ,
FBI ,
Homeland Security Cybersecurity & Infrastructure Security Agency (CISA) ,
Personal Data ,
Popular ,
Regulatory Reform ,
Russia ,
Ukraine ,
vuln
We are delighted to welcome you to the second issue of Dechert Cyber Bits, brought to you by members of our top-ranked, global Privacy & Cybersecurity practice. This second issue of Cyber Bits discusses key developments from...more
11/5/2021
/ Artificial Intelligence ,
Biometric Information ,
Cyber Attacks ,
Cybersecurity ,
Data Breach ,
Data Collection ,
Data Privacy ,
Federal Trade Commission (FTC) ,
Gramm-Leach-Blilely Act ,
Notification Requirements ,
Popular ,
Ransomware ,
Risk Management
Introduction - The European Commission’s (EC) proposed regulation (Proposed Regulation) for “trustworthy” Artificial Intelligence (AI) systems establishes rules for the development, placement on the EU market, and use of AI....more
This OnPoint summarizes key provisions of the European Commission's Proposed Regulation on Artificial Intelligence and offers some practical takeaways and strategic considerations for impacted organizations. Given the...more