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And the Modified Proposed CCPA Regulations are Here!

By Craig Cardon, Rachel Tarko Hudson, Liisa Thomas & Julia Kadish

February 13, 2020

On February 10, the California Attorney General’s office released a highly anticipated updated draft of the proposed CCPA regulations. This draft corrected a version first issued on February 7, 2020. These latest updates follow the four public hearings held in December 2019 and nearly 1,700 pages of comments submitted after the AG first released the initial proposal in October 2019. While these modified regulations are still not final, some of the notable changes include:…

Eye On Privacy

CMMC Version 1.0: Enhancing DOD’s Supply Chain Cybersecurity

By Jonathan E. Meyer & Townsend Bourne

February 12, 2020

Cybersecurity Maturity Model Certification (“CMMC”) v.1.0, after releasing several draft versions of the document over the past year. In an effort to enhance supply chain security, the CMMC sets forth unified cybersecurity standards that DOD contractors and suppliers (at all tiers, regardless of size or function) must meet to participate in future DOD acquisitions. Through the CMMC, DOD adds cybersecurity as a foundational element to the current DOD acquisition criteria of cost, schedule, and…

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FTC Finalizes Five Settlements Regarding Privacy Shield Claims

By Elfin Noce

January 22, 2020

The FTC recently finalized settlements with five companies over allegations that they falsely claimed certification under the EU-U.S. Privacy Shield framework. In each complaint, the FTC alleged that DCR Workforce, Inc., Thru, Inc., LotaData, Inc., and 214 Technologies, Inc. made false and misleading representations when they stated that they participated under the Privacy Shield framework on their website when they were not participants under the framework. Additionally, in the complaint against EmpiriStat, …

Eye On Privacy

New Trends Emerge in FTC Data Security Orders, Including Emphasis on C-Suite Involvement

By Julia Kadish

January 15, 2020

The FTC recently summarized three major changes it made to its orders in data security cases. In a blog signaling these changes, the FTC Indicated that some of the things it has been requiring of companies in 2019 are here to stay.…

Eye On Privacy

Getting Prepared for a Decade of Privacy

By Liisa Thomas

January 14, 2020

As we get settled into the reality of living with both CCPA and GDPR, companies are looking for new approaches for keeping their privacy houses in order. CCPA reminds us that there is no end to new legislation: proposals are already coming in from states as varied as Nebraska, New Hampshire and Virginia. Similar legislative trends exist around the globe. How can companies be prepared to address this ever shifting legislative landscape? There…

Eye On Privacy

Iran’s Imminent Cybersecurity Threat

By Jonathan E. Meyer

January 7, 2020

In response to the killing of Major General Qassim Suleimani, the government of Iran and its supreme leader, Ayatollah Ali Khamenei, have declared the country’s intention to strike back at the United States. According to reports, their desire is to respond proportionally, but not start a war, and they are contemplating multiple options, any subset of which they may implement.…

Eye On Privacy

Is Your Privacy Policy Ready for 2020?

By Julia Kadish & Liisa Thomas

December 19, 2019

Many organizations are currently focused on updating their privacy policy to include content required by CCPA. While making those edits, now is a good time to take a step back and think more broadly about privacy program and operations generally, and in particular about the non-CCPA parts of your privacy policy.…

Eye On Privacy

NAI’s 2020 Code Effective January 1 Along with CCPA

By Liisa Thomas, Elfin Noce & Julia Kadish

December 17, 2019

The Network Advertising Initiative, which provides guidance to advertisers who engage in personalized advertising, updated its Code of Conduct (2020 Code) earlier this year to address, inter alia, data collected offline and used for tailored advertising, as well as CCPA and TV-based tailored advertising. In anticipation of the January 1, 2020 effective date of the Code, the NAI recently issued a guidance on how to get “opt-in consent.” While the NAI Code and…

Eye On Privacy

New European Data Protection Board Guidance on Data Protection by Design and by Default

By Liisa Thomas, Kari Rollins & Elfin Noce

December 10, 2019

The European Data Protection Board recently requested comments on its data protection “by design and default” guidelines. Comments are due by mid-January of next year. The Guidelines provide clarity about how to address GDPR’s requirement that companies take “appropriate” technical and organizational steps to protect personal information and individuals. Part of the law’s requirements, according to the guidelines, is that companies can show that the measures they took are effective.…

Eye On Privacy

New Artificial Intelligence Law for Illinois Employers in January 2020

By Julia Kadish & Liisa Thomas

December 3, 2019

January 1, 2020, organizations that employ individuals based in Illinois will need to keep in mind the Artificial Intelligence Video Interview Act. This Act sets forth new requirements for video-recorded interviews using AI to analyze such recordings. The law is not limited to just Illinois residents. It applies to applicants for positions based in Illinois. While brief, and without any definitions, the Act requires three things before using AI technology in video interviews.…

Eye On Privacy

Timely Updates and Analysis on Privacy and Cybersecurity Issues

Blog Authors

And the Modified Proposed CCPA Regulations are Here!

CMMC Version 1.0: Enhancing DOD’s Supply Chain Cybersecurity

FTC Finalizes Five Settlements Regarding Privacy Shield Claims

New Trends Emerge in FTC Data Security Orders, Including Emphasis on C-Suite Involvement

Getting Prepared for a Decade of Privacy

Iran’s Imminent Cybersecurity Threat

Is Your Privacy Policy Ready for 2020?

NAI’s 2020 Code Effective January 1 Along with CCPA

New European Data Protection Board Guidance on Data Protection by Design and by Default

New Artificial Intelligence Law for Illinois Employers in January 2020

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