In a class action with potentially significant impact on data sharing disclosures that companies routinely provide in online privacy policies, the Third Circuit recently ruled that NaviStone, a third party marketing service, was not a “direct party” under the Pennsylvania
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CFPB Warns Failure to Safeguard Consumer Data May Be Unfair Act or Practice
The CFPB recently published a circular confirming that covered persons and service providers under the Consumer Financial Protection Act (CFPA) may violate the CFPA’s prohibition against unfair acts or practices when they fail to adequately safeguard consumer information. However, the
FTC Takes Aim at “Commercial Surveillance”
In an active week for federal regulators, the Federal Trade Commission (FTC) joined the CFPB in announcing important initiatives that may change privacy and data security practices in major ways.
On August 11, the FTC released its Advanced Notice of
NYDFS Announces Draft Amendments to Cybersecurity Regulation
On July 29, 2022, the New York Department of Financial Services (“NYDFS”) released Draft Amendments to its Cyber Security Regulations. The Amendments, if adopted, would further regulatory trends and impose important new requirements on covered entities.
The Amendments contain
Privacy Primer for Startups
Greg Szewczyk and Phil Yannella sat down with Kimberly Klayman to give a privacy update for startups in Technical.ly. Read the full interview here.
Webinar Recording – The Latest Wave of VPPA Litigation
In the latest episode in our monthly webcast series, Privacy and Data Security practice co-leaders Phil Yannella and Greg Szewczyk discuss the past, present, and future of VPPA litigation and proactive steps to mitigate the risk of VPPA litigation.
CPPA Announces Public Hearing on CPRA Regulations
The California Privacy Protection Agency announced today that it began the formal rulemaking process to adopt the proposed regulations implementing the Consumer Privacy Rights Act of 2020 (“CPRA”). As part of this announcement, the Agency released the following link to
OCC Highlights Risks Associated with Compliance Staffing Concerns, Russia Sanctions, Environmental Crimes, Cyber Attacks and Digital Assets
On June 23, 2022, the Office of the Comptroller of the Currency (OCC) released its Semiannual Risk Perspective (SRP) for spring 2022. In the SRP, the OCC opines on its current safety and soundness concerns for banks under its regulatory
GAO Report Recommends DHS and Treasury Assess Federal Response to Cyber Attacks
In a report released June 21, 2022, the U.S. Government Accountability Office (GAO) urged the Department of Homeland Security’s (DHS) Cybersecurity and Infrastructure Security Agency (CISA) and the Department of the Treasury’s (Treasury) Federal Insurance Office (FIO) to jointly assess
Third Circuit Upholds Federal Cyber-Stalking Statute Against Constitutional Challenge
The Third Circuit recently issued an opinion upholding the federal cyber-stalking statute against a constitutional challenge in United States v. Ho Ka Yung. Yung was convicted of cyber-stalking after he instituted a campaign of harassment against a Georgetown Law alumnus