Many privacy professional may have missed it, but In the run-up to the New Year — while many U.S. companies were focused on complying with the California Privacy Rights Act (CPRA) — Congress passed an appropriations bill that contains significant
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2023 Privacy and Data Security Preview
2022 proved to be an historic year for privacy and data security. Connecticut and Utah joined the list of states that have now passed comprehensive data privacy laws, bringing the total to five (5) states. For the first time, federal
Privacy, Cybersecurity and Access to Beneficial Ownership Information: FinCEN Issues Notice of Proposed Regulations Under the Corporate Transparency Act
A Deep Dive Into FinCEN’s Latest Proposals Under the CTA
On December 16, the Financial Crimes Enforcement Network (“FinCEN”) issued a 54-page notice of proposed rulemaking (“NPRM”) regarding access by authorized recipients to beneficial ownership information (“BOI”) that will be
The Cost of a Click: Microsoft fined 60 Million Euros by French Privacy Watchdog for French Data Protection Act Violations
On December 22, 2022, France’s National Commission for Technology and Freedoms (“CNIL”) fined Microsoft’s Irish subsidiary 60 million euro for failure to comply with Article 82 of the French Data Protection Law (known as the “Loi Informatique et Libertés”). Article
Colorado Releases Revised Privacy Rules
On December 21, the Colorado Attorney General released a revised draft of the Colorado Privacy Act Rules.
We will be providing in-depth analysis in coming days and weeks, but at first review, the revised rules appear to represent a fine-tuning
Pennsylvania Amends Data Breach Notification Law
In early November, Pennsylvania amended its data breach notification law broadening the definition of personal information. The amendment adds “health insurance information” and “medical information” as data elements that could trigger breach notification requirements. Coupled with this addition is a
Webinar Recording – The Colorado Privacy Act and Draft Rules
With its draft rules, Colorado has set forth a new model for state privacy laws. While there are many areas that are interoperable with the California model, the Colorado draft rules include important differences, as well as rules on topics
European Court Puts the Brakes on AML Directive: Public Access to Beneficial Ownership Database Violates European Privacy Laws
Ruling Could Influence FinCEN in Forthcoming Regulations Under the CTA
On November 22nd, an appeals court in Luxembourg issued a decision that highlights the tensions between anti-money laundering (“AML”) goals and privacy concerns, and could impact impending beneficial ownership regulations
FTC Extends Deadline by Six Months for Updated Safeguards Rule
On November 15, 2022, the FTC announced that it was extending by six months the deadline for companies to comply with some portions of the updated Safeguards Rule. The extension comes as a welcome relief to companies racing to meet
NYDFS Announces Updated Cybersecurity Regulation
On November 9, 2022, New York Department of Financial Services (NYDFS) Superintendent Adrienne Harris announced that the NYDFS formally proposed an updated cybersecurity regulation. Although the updates had previously been released in draft form, the formal announcement commences the