Timothy Tobin

Firm/Organization: Hogan Lovells

Blogs: Global Media and Communications Watch, HL Chronicle of Data Protection

Latest Articles

IAB Soliciting Comments on Draft Compliance Framework for Programmatic Advertising under the CCPA

By Bret Cohen, Timothy Tobin, James Denvil, Britanie Hall & Filippo Raso

October 31, 2019

On October 22, the Interactive Advertising Bureau (IAB), a media and marketing industry trade group, released for public comment the California Consumer Privacy Act Compliance Framework for Publishers and Technology Companies (Framework) and accompanying technical specifications to implement the Framework. The draft Framework is designed to help Framework participants (including publishers and intermediaries) comply with the California Consumer Privacy Act (CCPA) by: (1) establishing a digital signal that Framework participants can use to communicate consumer…

HL Chronicle of Data Protection

California AG Releases Proposed CCPA Regulations

By Mark Brennan, Timothy Tobin, Bret Cohen, Melissa Bianchi, Ryan Woo, Jonathan Hirsch & Julian Flamant

October 11, 2019

On October 10, California Attorney General Xavier Becerra (CA AG) released proposed regulations to implement certain provisions of the California Consumer Privacy Act (CCPA). The CA AG also released a Notice of Proposed Rulemaking and Initial Statement of Reasons that provide drafting insights and outline considerations that likely will continue to guide the rulemaking process. The CA AG is accepting written comments from the public until 5:00pm (PST) on December 6, 2019. The proposed regulations…

HL Chronicle of Data Protection

The Results Are in: Modest Changes to CCPA Await the Governor’s Signature

By Timothy Tobin, Mark Brennan, Scott Loughlin & Jonathan Hirsch

September 25, 2019

Since the California Consumer Privacy Act’s (CCPA) hasty passage in June last year and minor changes last September, the CCPA has vexed businesses working on compliance. Among many practical challenges, the CCPA often includes inconsistent or ambiguous requirements that have been an obstacle to implementing clear compliance strategies. Businesses, some academics, and various legislators thought that further amendments were needed to make the CCPA work effectively and accomplish its objectives. Over the past several…

HL Chronicle of Data Protection

Reminder that the FTC is Providing an Opportunity to Comment on COPPA Rule by October 23

By Timothy Tobin, Laurie Lai, Catherine Essig & Marco Peraza (Summer Associate)

September 5, 2019

The Federal Trade Commission (“FTC”) is requesting public comments on the Children’s Online Privacy Protection Rule (“COPPA Rule”). In particular, the FTC is seeking feedback on the effectiveness of its 2013 amendments to the COPPA Rule and on whether additional changes are needed. Comments are due October 23, 2019. The FTC will also be hosting a COPPA workshop on October 7, 2019.…

Global Media and Communications Watch

New Nevada Privacy Law With “Sale” Opt-Out Right Will Take Effect Before the CCPA

By Timothy Tobin, Mark Brennan, Scott Loughlin & Ryan Woo

June 4, 2019

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Nevada has a new privacy law. On May 29, Nevada Governor Steve Sisolak signed Senate Bill 220 (SB-220) into law, making Nevada the first state to join California in granting consumers the right to opt out of the sale of their personal information. The act, which amends an existing online privacy notice law, is significantly narrower than the California Consumer Privacy Act (CCPA). It applies only to online activities, defines “consumer” and “sale”…

HL Chronicle of Data Protection

New Nevada Privacy Law With “Sale” Opt-Out Right Will Take Effect Before the CCPA

By Timothy Tobin, Mark Brennan, Scott Loughlin & Ryan Woo

June 3, 2019

HL Chronicle of Data Protection

Cybersecurity Standards for the Insurance Sector – A New Patchwork Quilt in the US?

By Harriet Pearson, Timothy Tobin & Morgan Perna

May 13, 2019

In the past two years, multiple state bills that have been introduced in the US to provide for cybersecurity requirements and standards to the insurance sector, with recent legislative activity taking place in particular within the States of Ohio, South Carolina, and Michigan. The entering into effect of multiple state laws in this area may present challenges for insurance providers operating in states where such cybersecurity requirements are provided for.…

HL Chronicle of Data Protection

FTC Seeks Comment on Proposed Changes to GLBA Implementing Rules

By Timothy Tobin, Paul Otto & Roshni Patel

March 14, 2019

The Federal Trade Commission (“FTC”) issued notices on March 5 seeking public comment on proposed amendments to the regulations implementing the Gramm-Leach-Bliley Act (“GLBA”), commonly known as the Safeguards Rule and Privacy Rule. Once the notices are published in the Federal Register comments must be received within 60 days. The proposed changes to the Safeguards Rule add a number of more detailed security requirements, whereas the proposed changes to the Privacy Rule are more…

HL Chronicle of Data Protection

FTC Obtains Record COPPA Settlement

By Timothy Tobin, Britanie Hall, James Denvil & Catherine Essig

March 1, 2019

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On February 27, 2019, the Federal Trade Commission (“FTC”) announced that it settled with the operators of a video social networking app for a record civil penalty of $5.7 million under the Children’s Online Privacy Protection Act (“COPPA”). This FTC COPPA action was notable not just for the size of the penalty, but also because of the joint statement by the two Democratic Commissioners, Rebecca Slaughter and Rohit Chopra, that future FTC enforcement should seek…

Global Media and Communications Watch

California DoJ Sets March 8 Deadline for CCPA Pre-Rulemaking Comments

By Timothy Tobin, Harriet Pearson, Mark Brennan, Bret Cohen & Ryan Woo

February 5, 2019

The California Department of Justice has announced a March 8, 2019 deadline for submitting written pre-rulemaking comments on the California Consumer Privacy Act (CCPA). The March 8 deadline is an extension from the previously set end-of-February deadline. Pursuant to section 1798.185(a) of the CCPA, the California Attorney General (AG) is obligated to solicit broad public participation and adopt regulations to further the purposes of the CCPA. The CCPA sets out seven specific areas for AG…

Timothy Tobin

IAB Soliciting Comments on Draft Compliance Framework for Programmatic Advertising under the CCPA

California AG Releases Proposed CCPA Regulations

The Results Are in: Modest Changes to CCPA Await the Governor’s Signature

Reminder that the FTC is Providing an Opportunity to Comment on COPPA Rule by October 23

New Nevada Privacy Law With “Sale” Opt-Out Right Will Take Effect Before the CCPA

New Nevada Privacy Law With “Sale” Opt-Out Right Will Take Effect Before the CCPA

Cybersecurity Standards for the Insurance Sector – A New Patchwork Quilt in the US?

FTC Seeks Comment on Proposed Changes to GLBA Implementing Rules

FTC Obtains Record COPPA Settlement

California DoJ Sets March 8 Deadline for CCPA Pre-Rulemaking Comments

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