News & Analysis as of

Sensitive Personal Information

Pillsbury Winthrop Shaw Pittman LLP

DOJ Releases Its Data Security Program Compliance Guide

The guide outlines the requirements of a newly implemented Data Security Program designed to prevent China, Russia and other foreign adversaries designated by the U.S. Department of Justice from accessing American’s sensitive...more

Clark Hill PLC

DOJ implements new rule restricting bulk transfers of sensitive personal data

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On April 22, FTC Commissioner Melissa Holyoak delivered the opening keynote at the IAPP Global Summit, where she emphasized the importance of vigorously enforcing privacy laws while warning against stretching the FTC’s...more

Faegre Drinker Biddle & Reath LLP

California SB 354: A New Era in Insurance Consumer Privacy

The past few years have seen a surge of activities from states with respect to the introduction and adoption of consumer privacy bills. These bills vary from state to state, but generally include requirements around data...more

Baker Donelson

DOJ Issues Additional Guidance and Clarification on the Bulk Data Transfer Rule: What U.S. Businesses Need to Know

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On April 11, 2025, the Department of Justice's National Security Division (NSD) issued additional guidance to assist U.S. organizations in understanding and complying with the Data Security Program (DSP). As discussed in our...more

Kelley Drye & Warren LLP

The Bulk Data Access Rule: What Advertisers Need to Know

On April 11, the Department of Justice issued an extensive set of FAQs on its Bulk Data Access Rule and advised that it ​“will not prioritize civil enforcement actions against any person for violations” of the Rule through...more

Wiley Rein LLP

FTC Commissioner Holyoak Highlights Privacy Priorities in IAPP Keynote

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IAPP’s Global Privacy Summit kicked off on April 22 with keynote remarks from Federal Trade Commission (FTC) Commissioner Melissa Holyoak, who highlighted her top priorities for privacy enforcement and the digital economy. ...more

Goodwin

The Impact of Trump’s Executive Order on Eliminating Information Silos

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Hello, everyone. My name is Allan Medina. I am a partner in Goodwin’s Washington, DC, office, with a practice focus on government investigations. I’m here with Liza Craig, who is also a partner in the DC office. We are...more

WilmerHale

DOJ Issues Guidance for New Data Security Program

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On April 8, the Department of Justice’s (“DOJ’s”) final rule on Preventing Access to US Sensitive Personal Data and Government-Related Data by Countries of Concern or Covered Persons (the “Rule”) formally took effect. ...more

The Volkov Law Group

DOJ Issues Data Security Program Requirements (Part I of II)

The Volkov Law Group on

Many “good government” initiatives continue to be enacted or implemented on Capitol Hill or in the Executive Branch — notwithstanding changes in political control. While working on Capitol Hill, the bulk of the legislative...more

Womble Bond Dickinson

Navigating the New DOJ Data Security Program Compliance

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On January 8, 2025, the U.S. Department of Justice (“DOJ”) issued its final rule to implement Executive Order 14117 aimed at preventing access to Americans' bulk sensitive personal data and government-related data by...more

Troutman Pepper Locke

California AG Announces Investigative Sweep Targeting Geolocation Data

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On March 10, California Attorney General (AG) Rob Bonta announced an investigative sweep of the location data industry for potential noncompliance with the California Consumer Privacy Act (CCPA)....more

Mayer Brown

Department of Justice Releases Compliance & Enforcement Guidance on Data Security Program

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On April 11, 2025, the Department of Justice (DOJ) announced additional guidance regarding the implementation of the Final Rule (the “Rule”), Provisions Pertaining to Preventing Access to U.S. Sensitive Personal Data and...more

Dorsey & Whitney LLP

DOJ Limits Enforcement During First 90 Days of US-China Data Export Rules

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In a Press Release issued April 11, 2025, the U.S. Department of Justice (“DOJ”) indicated that it would prioritize “facilitating compliance” over civil enforcement actions for the first 90 days of its new US-China data...more

Goodwin

Life Sciences Companies Must Navigate the DOJ Data Rule

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Life sciences companies have long been outside the scope of US national security regulations and benefited from significant exemptions under US privacy laws. ...more

Ropes & Gray LLP

DOJ Releases FAQs and Compliance Guidance for Final Rule Restricting Flow of Bulk Sensitive Personal Data to China and other...

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On April 11, 2025, the Department of Justice (“DOJ”) released additional detail regarding the Final Rule implementing former President Biden’s Executive Order 14117, “Preventing Access to Americans’ Bulk Sensitive Personal...more

Littler

DOJ Rule Implementing Executive Order 14117 Regulating Cross-Border Data Transfers Takes Effect

Littler on

DOJ rule to implement Executive Order 14117, which restricts the exchange of sensitive personal data with certain “countries of concern,” took effect April 8. The order, which was issued under the prior administration,...more

McCarter & English, LLP

Follow the Breadcrumbs: Where Does Consumer Data Go as 23andMe Goes Bankrupt?

23andMe, a pioneer in the DNA testing kit industry, announced that it has filed for Chapter 11 bankruptcy protection and recently asked to select an independent customer data representative regarding any sale of user data....more

Benesch

New Data-Sharing Agreement Between DHS and IRS Will Impact Employers and Provide ICE with Unprecedented Access to Sensitive Data

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The Department of Homeland Security (“DHS”) and the Department of Treasury reached a data-sharing agreement in a Memorandum of Understanding (“MOU”) filed April 7, 2025....more

Baker Donelson

DOJ Final Rule Targets Cross-Border Data Transfers: Key Implications for U.S. and Foreign-Owned Companies Operating in the U.S.

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In the final days of the Biden administration the U.S. Department of Justice (DOJ) issued a sweeping set of regulations which are in effect as of yesterday, April 8, 2025. The regulations focus on cross-border data transfers...more

Ropes & Gray LLP

DOJ Bulk Data Final Rule Update

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Today, the Department of Justice’s (“DOJ”) Final Rule implementing former President Biden’s Executive Order 14117, “Preventing Access to Americans’ Bulk Sensitive Personal Data and United States Government-Related Data by...more

White & Case LLP

Oregon Releases Report on the First Six Months of its Oregon Consumer Privacy Act

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Oregon Attorney General Dan Rayfield has released a report detailing implementation steps and enforcement actions taken during the first six months of the Oregon Consumer Privacy Act ("OCPA"), which entered into force in July...more

Miller Canfield

DOJ Rule Restricting Sensitive Data Transfers Takes Effect

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Today, April 8, 2025, the U.S. Department of Justice’s Final Rule restricting transfers of bulk sensitive personal data and U.S. government-related data becomes effective, implementing former President Biden’s Executive Order...more

EDRM - Electronic Discovery Reference Model

“It Ends With Us”

In Lively v. Wayfarer Studios LLC, 2025 WL 662896 (S.D.N.Y. Feb. 28, 2025), the court granted in part and denied in part a motion to quash subpoenas issued to AT&T, Verizon, and T-Mobile (the “Wayfarer Parties”) by Ms. Blake...more

Goodwin

DOJ’s Data Export Rule Is In Force April 8: What You Need to Do

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On April 8, 2025, a sweeping rule issued by the US Department of Justice (DOJ) will take effect. The rule imposes restrictions—and in some cases, outright prohibitions—on US companies in connection with certain types of data...more

Wiley Rein LLP

Update: DOJ and CISA Issue New National Security Program to Regulate Foreign Access to Sensitive Data

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On January 8, 2025, the U.S. Department of Justice (Department or DOJ) issued new rules required by then-President Biden’s February 2024 Executive Order (EO) 14117 to establish a new regulatory framework aimed at “Preventing...more

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