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FTC Updates Health Breach Notification Rule

On July 1, 2024, the amendments to the Health Breach Notification Rule (HBNR) went into effect. First promulgated in 2009, the HBNR applies to vendors of personal health records — entities that are not covered by the Health...more

U.S. Protectionism in Health Data Flows

As privacy laws continue to proliferate in the U.S. and globally, there is one trend that companies, especially those operating in the health and pharmaceutical sectors, can no longer overlook. This is the trend towards data...more

Superior Court of California Prohibits Enforcing CPRA Regulations Until March 2024

On June 30, 2023, the Superior Court of California, County of Sacramento, Judge James Arguelles presiding, issued an order prohibiting the California Privacy and Protection Agency (the Agency) from enforcing regulations...more

Sephora Settles with California AG for $1.2M for Alleged CCPA Violations Relating to Third-Party Cookies and User-Enabled Opt-Out...

On August 24, 2022, California Attorney General Rob Bonta announced a settlement with Sephora for violations of the California Consumer Privacy Act (CCPA). The action places online consumer tracking, analytics and advertising...more

Zombie PHR Breach Rule Rises From the Dead

Yesterday, the FTC issued a policy statement announcing a new interpretation of the FTC’s 10-year-old “Personal Health Record Breach Notification Rule.” As the FTC acknowledges, this rule has never been enforced by the FTC....more

European Data Protection Board Issues New Recommendations for International Data Transfers: Essential Guarantees, Supplemental...

On November 11, 2020, the European Data Protection Board (EDPB) issued two much-anticipated guidance documents, outlining the approach it expects organizations to take when transferring data out of the EU. Although these...more

How We Spent Our Summer Vacation or Summary of CCPA Amendments

The long anticipated amendments to the CCPA were passed by the California Legislature in early September and now await Governor Newsom’s signature. Some of the changes were “clean up” amendments to update cross references,...more

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