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The California Privacy Protection Agency (“the Agency”) announced October 17, 2022, proposed modifications to the draft regulations for the California Privacy Rights Act (CPRA) that were published on July 8, 2022. The draft regulations expanded on the text of the CPRA setting out a number of additional requirements regarding obtaining consumer consent, supporting the exercise…

There has been a whirlwind of activity over the past year as states enact and implement comprehensive consumer privacy laws. Starting with the passage of the California Consumer Privacy Act (CCPA) in 2018, which became effective in 2020, the US state privacy legal landscape has continued to develop rapidly. New comprehensive privacy frameworks are set…

The California Privacy Rights Act (CPRA) will go into effect on January 1, 2023, even though the draft regulations remain unsettled, leaving companies questioning their ability to comply. In this talk with Jennifer Barrera of CalChamber, we’ll discuss some of the outstanding issues that will have impacts in the state, across the country, and, indeed,…

As cybersecurity and privacy risks mount, financial services companies face new concerns about compliance and enforcement as well as the risk of business interruption and costly litigation. In this Cybersecurity Awareness Month program, our lawyers will discuss the recent regulatory developments from the New York Department of Financial Services (NYDFS) that are presenting real-world challenges…

Online businesses that sell to California residents should take note of a recent enforcement action by the state’s attorney general (AG) signaling that adequate notice of sale must be provided in a business’s privacy policy, California residents’ opt-out requests must be honored, and, from the AG’s perspective, the use of third-party cookies for targeted advertising…

Connecticut has become the fifth state to pass comprehensive consumer data privacy legislation. Connecticut Governor Ned Lamont signed the bill into law on May 10, 2022, and the Connecticut Data Privacy Act” (CTDPA) will take effect on July 1, 2023. This Legal Update discusses the CTDPA’s scope; compares it with the other state privacy laws…

Following in the footsteps of California, Virginia and Colorado, Utah has become the fourth state to pass comprehensive consumer data privacy legislation. Utah Governor Spencer Cox signed Utah Consumer Privacy Act (“UCPA”) into law on March 24, 2022—the first major state law domino to fall in 2022 and the first comprehensive data privacy legislation since…

New comprehensive privacy frameworks in California, Virginia and Colorado are set to come into effect in 2023, and in recent days attention has turned to Utah, where a privacy bill closely resembling Virginia’s is on the governor’s desk for signature. The rulemaking processes for the enacted laws are in their early stages. To the chagrin…

On October 22, 2021, the New York Department of Financial Services (“NYDFS”) issued an interpretive letter that provides guidance on how entities regulated by NYDFS (“Covered Entities”) may comply with the NYDFS Cybersecurity Regulation by adopting the cybersecurity program of an affiliate (“Affiliate Program Letter”).1 According to the Affiliate Program Letter, a Covered Entity…

As cybersecurity and privacy risks mount, companies face new concerns about compliance and enforcement, as well as the risk of business interruption and costly litigation. In this National Cybersecurity Awareness Month program, our lawyers will discuss recent developments that are presenting real-world challenges.

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