News & Analysis as of

Tracking Systems Disclosure Requirements

Dechert LLP

Dechert Cyber Bits - Issue 58

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SEC Issues New Guidance as to 8-K Disclosures Relating to Cybersecurity Incidents - On June 27, 2024, the U.S. Securities and Exchange Commission (the “SEC”) issued new guidance on the agency’s guidelines for cybersecurity...more

Moore & Van Allen PLLC

New OCR Guidance on Tracking Technologies

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On March 18, 2024, the Office for Civil Rights ("OCR") at the U.S. Department of Health and Human Services ("HHS") published updated guidance on the use of online tracking technologies by HIPAA covered entities and business...more

Gardner Law

Amidst Legal Fight, HHS Revises Online Tracking Guidance

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On March 18, 2024, the Office for Civil Rights (OCR) of the U.S. Department of Health and Human Services (HHS) issued revised guidance on the use of tracking technologies by HIPAA-covered entities and business associates....more

Bass, Berry & Sims PLC

OCR Updates Guidance Regarding Compliance with HIPAA in Use of Online Tracking Technologies: Questions Remain

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On March 18, the U.S. Department of Health and Human Services (HHS) Office for Civil Rights (OCR) released updated guidance to “increase clarity” for entities regulated by the Health Insurance Portability and Accountability...more

Ankura

DHHS OCR and FTC Issue Warning to Hospital Systems and Telehealth Providers Regarding Privacy and Security Risks

Ankura on

On July 20, 2023, the Department of Health and Human Services (DHHS) through the Office of Civil Rights (OCR) and the Federal Trade Commission (FTC) issued a joint letter to hospitals and telehealth providers alerting them to...more

McDermott Will & Emery

For the General Counsel’s Desk: Managing Enforcement Risks Involving Cookies, Pixels, and Other Tracking Technologies

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Data governance is a mission-critical issue for every company and institution in the United States. GCs face a host of pressing cybersecurity concerns. Triaging them requires time, attention, and a well-rounded strategy...more

Dechert LLP

Dechert Cyber Bits - Issues 38

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SEC Finalizes Cybersecurity Disclosure Rules for Public Companies - On July 26, 2023, the Securities and Exchange Commission (“SEC”) voted to adopt new rules requiring public companies to make certain disclosures...more

Manatt, Phelps & Phillips, LLP

Advertising Law - February 2017 #4

Not-So-Smart TV: Vizio Settles Over Data Collection - For installing software on smart TVs and collecting viewing data on 11 million consumers without their knowledge or consent, Vizio, Inc. will pay the Federal Trade...more

King & Spalding

Vizio Pays $2.2 Million To Settle With The FTC Over Its Data Collection And Sharing Practices

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On February 6, 2017, Vizio Inc., a manufacturer and seller of internet-connected “smart” televisions, agreed to pay $2.2 million to settle allegations by the Federal Trade Commission (“FTC”) and the Office of the New Jersey...more

Mintz - Privacy & Cybersecurity Viewpoints

Who is Watching you Watch TV? If You Have VIZIO … Your TV Might Be Watching You

What does your TV-watching history say about you? According to a recent lawsuit against VIZIO, Inc., it might be more than you think! One of the world’s largest sellers of “smart” televisions has recently paid a $2.2 million...more

Alston & Bird

Smart Television Manufacturer Settles by Paying $ 2.2 Million to the FTC and the State of New Jersey

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The FTC and the State of New Jersey recently announced a settlement with Vizio, Inc., in the amount of $2.2 million for tracking consumer behavior using its smart television devices. The complaint alleged that Vizio...more

Lowndes

Big Brother and your TV – Vizio settles lawsuit with FTC and NJ Attorney General

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Vizio sold more than 11 million smart televisions since 2010. These televisions contained tracking devices which captured consumers’ IP addresses and television watching practices without alerting consumers or getting their...more

Ballard Spahr LLP

Disclosure Is Key for Cross-Device Tracking, FTC Staff Report Says

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If you or your third-party providers are engaged in cross-device tracking, you must adequately disclose the practice to your end users, provide them control over their information, and exercise care when collecting sensitive...more

Ballard Spahr LLP

To (Dis)Close for Comfort–FTC Workshop Seeks Effective Consumer Disclosures

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A goal of providing effective disclosures to consumers is to allow consumers to make informed decisions. But what must be done to make disclosures effective? This was the question the Federal Trade Commission (FTC) explored...more

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