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New Hampshire Enacts Comprehensive Privacy Law – SB 255

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

More Privacy, Please – November/December 2023

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

The Garden State Joins the Privacy Party

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

FTC's Sensitive Location Privacy Collection and Sale Expectations: Insights From Data Broker Settlements (and 10 Action Items to...

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

CFPB's Rulemaking Under the FCRA (Part 3) – Crossover Episode With The Consumer Finance Podcast [Audio]

Join us for the third episode in a special three-part series covering the CFPB's intention to propose new rules under the Fair Credit Reporting Act (FCRA). In this episode, Troutman Pepper Partners Chris Willis, Dave...more

More Privacy, Please – June 2023

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

Four Strategies for Drafting Effective Consumer Breach Notices

It is 2022, which means you’ve received your fair share of consumer breach notification letters. Originally published in Law360 on September 30, 2022....more

More Privacy, Please - September 2022

Editor’s Note: In the U.S. laws and regulation space, the California attorney general announced the first-ever CCPA settlement, the California Privacy Protection Agency raised objections to the ADPPA, and the FTC announced...more

CCPA/CPRA Will Apply to Employee AND B2B Data — Five Steps to Prepare for the January 1, 2023 Effective Date

Exemption Extensions Failed. On August 31, California's legislature ended its 2022 session without adopting legislation to extend the California Consumer Privacy Act (CCPA) employee and business-to-business (B2B) personal...more

Not So Pretty: Top Takeaways From First CCPA Settlement With Sephora and Updated Enforcement Case Examples

With the notice and cure set to expire on January 1, 2023, California Attorney General Rob Bonta (CA AG) provided a glimpse at what to expect with its first settlement of alleged violations of the California Consumer Privacy...more

More Privacy, Please - July 2022

Editor’s Note: In the U.S. laws and regulation space, federal lawmakers formally introduced bipartisan comprehensive federal privacy legislation titled, the American Data Privacy and Protection Act. Meanwhile, California...more

California Privacy Protection Agency Publishes Draft Rules

The California Privacy Rights Act (CPRA) established the California Privacy Protection Agency (CPPA), and requires the CPPA to adopt, amend, and rescind regulations on 22 topics — including, among other things, definitions,...more

CPRA Series: Part Four – Data Processing Obligation

The California Privacy Rights Action (CPRA) will significantly impact how entities process personal information requiring covered businesses to review and update their existing vendor agreements. The CPRA also includes...more

CPRA Series: Part Two – Consumer Rights

Most privacy laws derive from the same core foundational principles, namely the Fair Information Practice Principles (FIPPs). This includes the California Consumer Privacy Act of 2018 (CCPA), California Privacy Rights Act of...more

Colorado Governor Signs Comprehensive Data Privacy Bill — How Does It Compare to California and Virginia?

On July 7, Governor Jared Polis signed Colorado's comprehensive data privacy bill (SB 21-190) into law. The Colorado Privacy Act (CPA) will go into effect on January 1, 2023, making Colorado the third state to enact a...more

Colorado Passes Comprehensive Data Privacy Law

On June 8, the Colorado legislature passed the Colorado Privacy Act (CPA). Assuming Governor Jared Polis signs the bill into law within 30 days, as is expected, Colorado will become the third state in the United States to...more

More Privacy, Please - April 2021

Do you want a simple way to keep current on important privacy changes? Avoid sleepless nights wondering whether you missed a privacy speed bump or pothole between annual updates? Worry no longer. Troutman Pepper is pleased to...more

Litigation and Enforcement: Virginia Consumer Data Protection Act Series (Part Five)

Like the California Consumer Privacy Act of 2018 (CCPA) and the California Privacy Rights Act of 2020 (CPRA), the Virginia Consumer Data Protection Act (VCDPA) does not grant a private right of action for alleged violations...more

California AG Announces Approval of Fourth Set of Modifications to CCPA Regulations

On March 15, California Attorney General Xavier Becerra announced that the California Office of Administrative Law approved his fourth set of proposed modifications to the California Consumer Privacy Act’s (CCPA) implementing...more

Virginia Consumer Data Protection Act Series: Consumer Rights

As we noted in Part One of this Series, which provides an introduction and overview of the Virginia Consumer Data Protection Act, most privacy laws – including those adopted in the United States – are built on the Fair...more

More Privacy, Please - March 2021

Do you want a simple way to keep current on important privacy changes? Avoid sleepless nights wondering whether you missed a privacy speed bump or pothole between annual updates? Worry no longer. Troutman Pepper is pleased to...more

Virginia Consumer Data Protection Act Series

We have long predicted that just as other states followed California in passing breach notification laws, states would follow in California’s footsteps in regulating information privacy practices with the California Consumer...more

More Privacy, Please - January 2021

Do you want a simple way to keep current on important privacy changes? Avoid sleepless nights wondering whether you missed a privacy speed bump or pothole between annual updates? Worry no longer. Troutman Pepper is pleased to...more

California AG Releases Fourth Set of Proposed Modifications to CCPA Regulations

On December 10, the California attorney general released the fourth set of proposed modifications (Proposed Modifications) to the implementing regulations of the CCPA. These Proposed Modifications come only one month after...more

Californians Pass CPRA, Expanding Consumer Privacy Protections

California voters passed Proposition 24 in last week’s general election to adopt the California Privacy Rights Act of 2020 (CPRA), which amends the California Consumer Privacy Act of 2018 (CCPA) in several ways intended to...more

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