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Insurance Cybersecurity Certifications: An (Updated) State Roundup

Over half of US states require annual compliance certifications from insurance providers. While the filing time frames for this year draw to a close, companies may want to keep them in mind not only for next year, but as a...more

Arkansas’ Kids Social Media Law: Another One Bites the Dust

Arkansas’ second attempt at regulating minor’s access to social media – in the form of the Social Media Safety Act (SB 689) – has again been struck down as unconstitutional. The court permanently enjoined the state from...more

Auto Insurer Settles With New York AG Over Insurance Application Platform Security Issues

The New York Attorney General recently entered into an assurance of discontinuance with Root Insurance Company following a 2021 data incident. According to the AG, the threat actors obtained people’s drivers’ license numbers...more

US State AI Legislation: Virginia Vetoes, Colorado (Re)Considers, and Texas Transforms

The Virginia law, like the Colorado Act, would have imposed various obligations on companies involved in the creation or deployment of high-risk AI systems that influence significant decisions about individuals in areas such...more

SEC Creates New Tech-Focused Enforcement Team

On February 20, the SEC announced the creation of its Cyber and Emerging Technologies Unit (CETU) to address misconduct involving new technologies and strengthen protections for retail investors. The CETU replaces the SEC’s...more

Utah Pioneers App Store Age Limits

Utah’s governor recently signed the first law which puts age restrictions on app downloads. The law (the App Store Accountability Act, SB 142), was signed yesterday (Wednesday, April 26, 2025). We anticipate that the law may...more

Oregon’s Privacy Law: Six Month Update, With Six Months to End of Cure Period

Oregon’s Attorney General released a new report this month, summarizing the outcomes since Oregon’s “comprehensive” privacy law took effect six months ago. A six-month report isn’t new: Connecticut released a six month report...more

New York AG Settles with School App

The New York Attorney General recently entered into an assurance of discontinuance with Saturn Technologies, operator of an app used by high school and college students. The app was designed to be a social media platform that...more

Common Privacy Pitfalls in M&A Deals

Many expect that deal activity will increase in 2025. As we approach the end of the first quarter, it is helpful to keep in mind privacy and data security issues that can potentially derail a deal. We discussed this in a...more

FTC Requests Input from Tech Platform Users About Speech

The Federal Trade Commission recently requested public comment from users of tech platforms. In particular, the impact the platforms may have on user speech. Input is sought -by May 21- on the extent to which tech firms are...more

Forget It!: EDPB Announces Focus on Right to Erasure in 2025

Right of erasure (or “right to be forgotten”) has been selected by the European Data Protection Board as its priority enforcement topic for 2025. This work is being done under the “Coordinated Enforcement Framework” or “CEF.”...more

FTC COPPA Updates Provide New Protections for Children

In the waning days of the Biden administration, the FTC published an update to its COPPA Privacy Rule. The status of this update, however, is unclear. The revisions to the rule were posted on the FTC website prior to the...more

Oregon’s AI Guidance: Old Laws in Scope for New AI

The Oregon AG’s Office, along with the state’s Department of Justice, issued guidance late last year on how state laws apply to the ways businesses use AI. The guidance may be two months old, but the cautions are still...more

New Jersey Updates Discrimination Law: New Rules for AI Fairness

The New Jersey AG and the Division on Civil Rights’ new guidance on algorithmic discrimination explains how AI tools might be used in ways that violate the New Jersey Law Against Discrimination. The law applies to employers...more

New Year, Old Tradition: CPPA Focuses on Unregistered Data Brokers

The California privacy regulator recently settled with a data broker (Key Marketing Advantage LLC) that it alleged had violated the state’s data broker law. Under the Delete Act, data brokers must, among other things,...more

California’s Kids’ Social Media Law Wrangling Continues, and Maryland Too!

The Ninth Circuit continued the pause on California’s SB 976 (Protecting Our Kids from Social Media Addiction Act) as of late January 2025. The law was signed by Governor Newsom in September 2024, and challenged by NetChoice...more

EU Fines EU?!: Alleged Unlawful Data-Transfer Dust-Up

Following a German case brought against the EU Commission, the EU General Court found that the Commission had made an improper transfer of personal information to the US. The plaintiff, a German citizen, alleged (among other...more

Don’t Forget the EU: Italy Issued First GenAI Fine of €15 Million Alleging GDPR Violations 

At the end of 2024 the Italian Data Protection Authority issued a 15 million euro fine in the first generative AI-related case brought under GDPR. According to Garante (the Italian authority), OpenAI trained ChatGPT with...more

Sheppard Mullin’s 2024 Eye on Privacy Year in Review

It is hard to believe that another year is upon us! As we have done in years past (including 2023, 2022, 2021, 2020, 2019 and 2018), we have created a comprehensive resource of all our www.eyeonprivacy.com posts from 2024. As...more

Colorado Rolls Out Updated Privacy Rules Ahead of 2025 CPA Amendments

The Colorado AG’s office adopted draft amendments to the Colorado Privacy Act rules last month. The adopted draft reflected input from the public to AG’s September 2024 version and addresses three key issues. First, on...more

New Year, New Protections for New York Artists and AI-Generated Replicas

New York has a new AI-related law which took effect January 1. The law regulates creation and use of digital replicas of an individual’s voice or likeness and is similar to those in California and Tennessee....more

New York Modifies Data Breach Law Heading Into 2025

As 2024 came to a close, New York Gov. Hochul signed two bills (A8872A and S2376B) amending New York’s data breach law. The modifications change both what constitutes personal information under the law, as well as modifying...more

FCC’s One-To-One Consent Rule Takes Effect in January

For those who send marketing texts, keep in mind the FCC one-to-one consent rule update. It has been getting some publicity, and takes effect January 27, 2025. As most are aware, TCPA requires getting consent before sending...more

FTC Keeps Sights on Data Brokers that Sell Sensitive Location Sites

The Federal Trade Commission recently settled complaints against two data brokers over their handling of consumers’ sensitive location information. The agency alleged that such practices constitute unfair practices. Under the...more

Coming to a State Near You: 5 State Privacy Laws Take Effect in January 2025

Are you ready for the next set of US state privacy laws going into effect? Delaware, Iowa, Nebraska, and New Hampshire are effective January 1, and New Jersey’s law go into effect two weeks later (January 15)....more

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