As recent events indicate, American companies may be the subject of destructive data “wiper” attacks and potential data theft by Iran-linked hackers. Ongoing tensions in the Middle East underscore the stark and evolving cyberthreat landscape facing companies. These types of
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HHS OCR Announces Civil Enforcement Program for Confidentiality of Substance Use Disorder Patient Records
On February 13, 2026, the U.S. Department of Health and Human Services (“HHS”), Office for Civil Rights (“OCR”) announced its civil enforcement program to implement the updates to the Substance Use Disorder (“SUD”) confidentiality provisions of the regulation at 42
Supreme Court to Consider the Video Privacy Protection Act
Last week, the U.S. Supreme Court agreed to hear a case that is expected to resolve a long-developing split among federal courts of appeals over the scope of the Video Privacy Protection Act of 1988 (“VPPA”), 18 U.S.C. § 2710.
On the Twelfth Day of Data… Privacy Litigation: Four Notable Developments From 2025
The past year was a busy one for privacy litigation: Website tracking litigation gained momentum. Plaintiffs repurposed legacy wiretap and video privacy statutes to target pixels, chat bots, and other AI-enabled user tools. Courts issued decisions that altered liability theories
On the Eleventh Day of Data… Unwrapping DSARs in 2026
As the year draws to a close, reform of the data subject access request (DSAR) regime in the EU and the UK may turn out to be a welcome gift for organisations grappling with complex access requests. Regulators in both
On the Tenth Day of Data… Looking Back at 2025 and Ahead to NYDFS Enforcement Priorities in 2026
While 2025 may have brought questions about the level of enforcement we would see from federal regulators, there was no question that state regulators would continue to be active, especially in the financial privacy space. In 2025, we saw the
On the Ninth Day of Data… State of the States: This Year’s Key Privacy Law Developments Across the U.S. States
The continued absence of a comprehensive federal privacy law once again positioned state legislatures as the primary forces behind data privacy developments in the U.S. this year. In 2025, eight new comprehensive state privacy laws took effect, adding to a
On the Eighth Day of Data… AI Regulation – A 2025 Recap and a Look Ahead to 2026
In 1950, reflecting on the future of machine intelligence, Alan Turing observed: “We can only see a short distance ahead, but we can see plenty there that needs to be done.” With several large language models, most notably OpenAI’s GPT-4.5,
On the Seventh Day of Data… The Growing Pains of Regulation S-P in 2025
Financial regulators including the Securities and Exchange Commission (“SEC”) continued to focus on data protection and cybersecurity issues throughout 2025. With the amendments to the Safeguards Rule and Disposal Rule of Regulation S-P officially taking effect, the SEC is continuing
On the Sixth Day of Data… CISA, CIRCIA, and the Future of Critical Infrastructure Security
This holiday season—following a year of headline breaches, surging supply-chain attacks, and major regulatory changes—cyber resilience tops every corporate wish list.
The Cybersecurity and Infrastructure Security Agency (“CISA”) remains at the forefront of U.S. cybersecurity amid a