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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

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

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

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

California’s Privacy Regulator Had a Busy November, Cybersecurity Audits and Insurance Edition: What Does It Mean for Businesses?

In the fourth in our series of new CCPA regulations from California, we look at both cybersecurity audit obligations as well as the impact of the CCPA on the insurance industry. Cybersecurity Audits The proposed rules address...more

How Legitimate Is Your Business Interest? The EDPB Has Some Thoughts

The European Data Protection Board issued draft guidelines last month that outline when processing can be considered done for “legitimate interest.” The public has until November 20 to provide comments to the draft....more

EDPB Provides Insight for Use of Tracking Tools

The EDPB released guidance last month to help companies understand their obligations when using newer tracking tools. These include pixels, URL tracking, IP-tracking, and the like. First, some background: an EU law that...more

California Joins Colorado in the Brain Wave Action

California’s governor has signed an amendment to CCPA, the state’s well-known privacy law. While California was the first to pass a “comprehensive” privacy law, it is the second -with this new amendment- to include “neural...more

California: Age-Appropriate Design Code Act Partially Blocked, New Social Media Law Signed

California has been active in the kids space. First, the Ninth Circuit’s recently ruled on the California’s Age-Appropriate Design Code Act. Second, the governor has just signed a new law aimed at social media sites....more

Malaysia In Process of Updating Its Privacy Law

Malaysia is in the process of updating its Personal Data Protection Act to align more closely with laws in other jurisdictions. The law was originally passed in 2010 and then modified this year. As part of the modification...more

October 1st Reminder – Big Sky Privacy Law Goes into Effect

2024 seems like it is flying by. For those keeping track of US state “comprehensive” privacy laws you know that October 1 – a week away – brings the effective date of the Montana privacy law. The “big sky” state will join...more

Brazil’s Data Protection Authority Issues Rules Clarifying Data Transfers

Wondering what the requirements are for transferring personal information out of Brazil? Under the country’s Data Protection Law, extra-territorial transfers of personal information are regulated in much the same way as in EU...more

New Data Breach Notification Obligations for PA – and a New Reporting Portal

Pennsylvania AG Michelle Henry announced yesterday the launch of an online portal for businesses to report data breaches to the AG’s office. The portal launch comes before Pennsylvania’s new breach amendments take effect on...more

Camera Company Will Pay $2.95 Million to Settle Security Claims

Verkada, a manufacturer and retailer of security cameras, has settled FTC accusations of lax security measures. The company sells its products to businesses, including schools and medical facilities. It markets its products...more

Biotech Company Settles with Three State AGs Over Security Practices

A biotech company recently settled with three AGs over allegations that it had failed to protect consumer information. According to the AGs of Connecticut, New York and New Jersey, this led to a 2023 data incident. The...more

NY AG Releases Website Privacy Guides for Businesses and Consumers

New York Attorney General Letitia James recently released guidance for businesses and consumers about website tracking technologies. The consumer guide provided examples of common cookies, tracking technologies, and how...more

Colorado’s Privacy Law Gets in on the Brain Wave Action

The amendment to the Colorado Privacy Act, expanding the scope of sensitive data, goes into effect August 6, 2024. The law will now include as sensitive information biological data that is used for identification purposes....more

Ring, Ring, it’s the FCC Calling- TracFone to Pay $16M to Settle FCC Investigation

TracFone, the pre-paid phone company, recently settled with the FCC over allegations that the company failed to protect customer information during three different data incidents. According to the FCC, in each of the...more

We Don’t Use Dark Patterns!? FTC and Consumer Protection Networks Review Suggests You Might

In its ongoing concern with “dark patterns,” the FTC recently announced results of two reviews of sites and apps purportedly engaging in the practice. As a reminder, the FTC views as “dark patterns” practices or web designs...more

The Land of 10,000 Lakes Adds New Consumer Privacy Law: Minnesota Joins Privacy Fray

Minnesota’s governor has now signed into law that state’s comprehensive privacy law. For those keeping count – that is number 19 of state “comprehensive” privacy laws, with six in 2024 alone. The Minnesota law will go into...more

Mid-Year Recap: Think Beyond US State Laws!

Much of the focus on US privacy has been US state laws, and the potential of a federal privacy law. This focus can lead one to forget, however, that US privacy and data security law follows a patchwork approach both at a...more

Maryland, the Old Line State, Creates New Lines with Consumer Privacy Law

Maryland’s new comprehensive data privacy law, the Maryland Online Data Privacy Act, was recently signed into law by Governor Moore. This brings the total number of state “comprehensive” privacy laws to 18, five of which have...more

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