In an era where privacy and security are paramount, understanding the range of potential vulnerabilities and risks faced by energy producers and EV manufacturers is crucial. Join Troutman Pepper Partners Jim Koenig and Chris...more
On July 5, the California Privacy Protection Agency (CPPA) published a Notice of Proposed Rulemaking regarding Data Broker Registration pursuant to Senate Bill 362 (the Delete Act). The Delete Act requires the CPPA to...more
Historically, many private equity firms have let their portfolio companies independently manage cybersecurity. Given the increase in data and cyber risks, sophistication of threat actors, and impact and cost of breaches,...more
On March 6, 2024, New Hampshire Governor Chris Sununu signed Senate Bill 255 into law, making New Hampshire the 14th U.S. state to enact a comprehensive privacy law. The law, which becomes effective on January 1, 2025, is...more
Editor’s Note: In recent regulatory and enforcement developments, the White House announced a new executive order aimed at strengthening cybersecurity at U.S. ports, and another executive order was issued to protect sensitive...more
3/7/2024
/ Artificial Intelligence ,
Biden Administration ,
Consent Order ,
Consumer Financial Products ,
Cybersecurity ,
Data Breach ,
Data Privacy ,
Data Protection ,
Department of Health and Human Services (HHS) ,
Executive Orders ,
Fair Credit Reporting Act (FCRA) ,
FCC ,
Financial Services Industry ,
Personal Data ,
Personally Identifiable Information ,
Robocalling ,
TCPA ,
UDAAP
In a recent alert, we reported that California Attorney General (AG) Rob Bonta announced a settlement with DoorDash over allegations that the company violated the California Consumer Privacy Act (CCPA) and the California...more
3/5/2024
/ California ,
California Consumer Privacy Act (CCPA) ,
CalOPPA ,
Data Privacy ,
DoorDash ,
Marketing ,
Mobile Apps ,
Personal Information ,
State and Local Government ,
State Attorneys General ,
Statutory Violations
In the second settlement under the California Consumer Privacy Act (CCPA), California Attorney General (AG) Rob Bonta announced a settlement over allegations that DoorDash sold consumers' personal information in a manner that...more
3/4/2024
/ California ,
California Consumer Privacy Act (CCPA) ,
CalOPPA ,
Data Privacy ,
DoorDash ,
Marketing ,
Mobile Apps ,
Personal Information ,
State and Local Government ,
State Attorneys General ,
Statutory Violations
NIST Publishes Report on the Cybersecurity of Genomic Data. On December 20, 2023, the NIST National Cybersecurity Center of Excellence (NCCoE) published Final NIST IR 8432, Cybersecurity of Genomic Data. Informed by direction...more
2/13/2024
/ Artificial Intelligence ,
Biometric Information ,
Biometric Information Privacy Act ,
Consumer Financial Products ,
Consumer Fraud ,
Cyber Attacks ,
Cybersecurity ,
Data Breach ,
Data Brokers ,
Data Privacy ,
Data Protection ,
Data Security ,
Federal Trade Commission (FTC) ,
Financial Services Industry ,
NIST ,
Personal Information ,
Personally Identifiable Information ,
Popular ,
Putative Class Actions
In recent regulatory and enforcement developments, the California Privacy Protection Agency (CPPA) proposed a regulatory framework for automated decision-making technology (ADMT) and revisions to the California Consumer...more
2/7/2024
/ Artificial Intelligence ,
California Consumer Privacy Act (CCPA) ,
California Privacy Protection Agency (CPPA) ,
Consumer Privacy Rights ,
COPPA ,
Cyber Attacks ,
Data Breach ,
Data Brokers ,
Data Protection ,
FCC ,
Federal Trade Commission (FTC) ,
Financial Services Industry ,
Personal Data ,
Popular ,
Reporting Requirements ,
Robocalling ,
Social Media ,
State Attorneys General ,
Vulnerability Assessments ,
Website Owner Liability
Troutman Pepper’s 2023 Privacy Year in Review is a comprehensive analysis of the year’s key developments in privacy, security, and artificial intelligence and offers practical advice for companies navigating the bewildering...more
On January 16, New Jersey Governor Phil Murphy signed S332 (the act), making New Jersey the first state in 2024 to enact a comprehensive privacy law. Several other states are currently considering similar comprehensive...more
1/26/2024
/ Consumer Privacy Rights ,
Cybersecurity ,
Data Collection ,
Data Privacy ,
Data Protection ,
Data Security ,
Information Technology ,
New Jersey ,
Personal Data ,
Personally Identifiable Information ,
Regulatory Reform ,
State Data Privacy Laws
Following several years of investigating the common practices in the space, the Federal Trade Commission (FTC) reached its first settlement with a data broker over the alleged collection and sale of location information that...more
1/18/2024
/ Consumer Financial Protection Bureau (CFPB) ,
Consumer Privacy Rights ,
Corporate Counsel ,
Data Brokers ,
Data Collection ,
Data Sellers ,
Data Selling ,
Fair Credit Reporting Act (FCRA) ,
Federal Trade Commission (FTC) ,
Geolocation ,
Location Data ,
Personal Data ,
Request For Information ,
Settlement
Editor’s Note: The FTC continues to crack down on privacy and cybersecurity, including issuing a new warning to tax preparation companies and entering into a consent decree with 1Health.io. VPPA and BIPA litigation continues...more
11/28/2023
/ Artificial Intelligence ,
Biometric Information Privacy Act ,
California Consumer Privacy Act (CCPA) ,
California Privacy Protection Agency (CPPA) ,
Consent Order ,
Cybersecurity ,
Data Breach ,
Data Protection ,
Executive Orders ,
Federal Trade Commission (FTC) ,
Final Rules ,
Financial Institutions ,
Gramm-Leach-Blilely Act ,
Motion to Dismiss ,
NIST ,
Personal Information ,
Popular ,
Privacy Policy ,
Putative Class Actions ,
Safeguards Rule ,
State Attorneys General
On October 27, the Federal Trade Commission (FTC) announced a final rule amending the Standards for Safeguarding Customer Information (Safeguards Rule) under the Gramm-Leach-Bliley Act. The Safeguards Rule requires nonbanking...more
Editor’s Note: As the summer months come to an end, there has been no shortage of privacy news and updates. Oregon signed both a comprehensive privacy law and data broker law, and the SEC adopted new rules regarding the...more
9/15/2023
/ Biometric Information ,
Biometric Information Privacy Act ,
California Consumer Privacy Act (CCPA) ,
Cybersecurity ,
Data Privacy ,
Data Protection ,
Data Security ,
Federal Trade Commission (FTC) ,
Fingerprints ,
Popular ,
Securities and Exchange Commission (SEC)
Generative artificial intelligence (AI) has seemingly infiltrated every aspect of corporate America, and organizations’ legal, compliance, and human resources departments are understandably struggling to keep pace with its...more
On July 26, the Securities and Exchange Commission (SEC) adopted, by a 3-2 margin, a final rule to require more immediate disclosure of material cybersecurity incidents by public companies. In addition, the final rule...more
CPRA Regulations Delayed. On June 29, 2023, two days before enforcement of the California Consumer Privacy Act (CCPA) was to begin, a Sacramento Superior Court issued a temporary injunction, enjoining enforcement of newly...more
Editor’s Note: Texas, Oregon, and Delaware became the latest states to pass a comprehensive privacy bill, while the CPRA, Connecticut, and Colorado’s privacy laws came into force. In the litigation world, the FTC filed an...more
7/20/2023
/ California Privacy Rights Act (CPRA) ,
Data Breach ,
Data Privacy ,
Department of Health and Human Services (HHS) ,
Fair Credit Reporting Act (FCRA) ,
Federal Trade Commission (FTC) ,
Financial Services Industry ,
Health Insurance Portability and Accountability Act (HIPAA) ,
New Legislation ,
Personal Data ,
Popular ,
Securities and Exchange Commission (SEC) ,
Small Business ,
State Data Privacy Laws
Background -
On July 1, an amendment to the Florida Electronic Health Records Exchange Act (the Act) will go into effect. The Act focuses on information safety and sets forth stringent requirements that prohibit health...more
Editor’s Note: Montana became the latest state to pass a comprehensive privacy bill, joining California, Virginia, Colorado, Connecticut, Utah, and Tennessee. Florida, too, passed a privacy bill, but with a much narrower...more
6/21/2023
/ Biometric Information ,
Consumer Privacy Rights ,
Data Breach ,
Data Privacy ,
Data Protection ,
Data Security ,
Federal Trade Commission (FTC) ,
Financial Services Industry ,
New Legislation ,
Popular ,
Regulatory Reform ,
State Data Privacy Laws
Editor’s Note: Indiana became the latest state to enact a comprehensive privacy law, with Montana and Tennessee close behind. Washington passed sweeping legislation — the My Health My Data Act — which included a private right...more
Online Tracking Technologies and HIPAA. In December 2022, the Department of Health and Human Services Office for Civil Rights (OCR) published a bulletin on the use of online tracking technologies (e.g., cookies or web...more
On April 27, the state of Washington enacted the My Health My Data Act (MHMDA), a comprehensive health privacy law that imposes broad restrictions on how “consumer health data” can be used by companies doing business in the...more
In recent months, there has been an explosion of artificial intelligence tools that have given even technophobes an opportunity to test AI’s power from the comfort of their favorite web browser.
Originally published in...more