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Ready Set Go: California Privacy Protection Agency Previews Draft Regulations

Less than two months after the California Privacy Protection Agency (“CPPA” or “Agency”) formally took over rulemaking for the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act...more

SEC Proposes New Cybersecurity Rules for SEC Registered Advisers and Funds

At an open meeting on February 9, 2022, the Securities and Exchange Commission voted three-to-one to propose new and amended rules regarding cybersecurity risk management, cyber incident reporting and cyber risk disclosure...more

Dechert Cyber Bits - Issue 6

On January 12, 2022, the French data protection authority (“CNIL“) published guidance on the reuse of personal data by processors for their own purposes (the “Guidance”)....more

Dechert’s Privacy & Cybersecurity Extended Forecast for 2022: Hot Today. Hotter Tomorrow!

​​​​​Few things are certain, but it is indisputable that in 2022 data will remain big; data driven technologies will create unparalleled opportunity and risk; the frequency and sophistication of cyberattacks will shatter...more

Baked & Wired: Potential Break in Impasse Over e-Privacy Regulation

On 10 February 2021, over two and a half years after the anticipated adoption of the e-Privacy Regulation, European Member States have agreed to a revised text. Portending a potential break in the three-year impasse, the...more

A Change is Coming: European Commission Releases Draft SCCS For Data Transfers

On November 12, 2020, the European Commission (EC) published a long anticipated draft of new Standard Contractual Clauses (SCCs) for the transfer of personal data from the European Economic Area (EEA) to third countries whose...more

German Antitrust Authority Finds Antitrust Infringement on the Basis of a Data Protection Breach

The German antitrust authority (FCO) has ordered Facebook to stop collecting data outside Facebook’s platform without the user’s “voluntary consent.” The decision breaks new ground because it links data protection and...more

SEC Staff to Conduct Broker-Dealer and Investment Adviser Examinations Focused on Cybersecurity

The Securities and Exchange Commission’s (the “SEC” or the “Commission”) Office of Compliance Inspections and Examinations (“OCIE”) announced in an April 15, 2014 Risk Alert (the “Alert”) that it will be conducting...more

Court Sides with FTC on Sweeping Data Security Role

Executive Summary: Federal Trade Commission v. Wyndham Worldwide Corp. A U.S. District Court has ruled this week that the Federal Trade Commission (FTC) has authority under Section 5 of the FTC Act to bring enforcement...more

SEC and CFTC Issue Identity Theft Red Flags Rules Applicable to Financial Institutions and Creditors

The SEC and CFTC recently issued joint Identity Theft Red Flags Rules (the “Rules”), which are rules and guidelines requiring certain financial institutions worldwide to adopt comprehensive data security programs to detect...more

Cybersecurity Disclosure: The Risks Of Silence

With the rise in targeted, sophisticated, malicious attacks on corporate America’s electronic infrastructure, companies are increasingly focused on their cybersecurity disclosure obligations. There is a growing concern that...more

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