Data Privacy

Privacy compliance has entered a new phase—one defined not only by high-profile enforcement actions but by the growing expectation that organizations implement and maintain mature information governance programs capable of validating true, system-level technical compliance rather than merely projecting the appearance of it.  A spate of recent California enforcement actions makes clear that companies must be prepared to validate how privacy control’s function, including across systems, platforms, and data flows, making thoughtful, system-oriented self-assessment an increasingly important tool for aligning policy commitments with operational reality—before regulators do it for them.  SPB helps client’s self-access, identify gaps and remediate issues under the cloak of privilege.Continue Reading CalPrivacy Update: Shifting to Structural Compliance and Auditing

On December 23, 2025, a federal judge enjoined enforcement of Texas’ App Store Accountability Act (SB 2420) by Texas Attorney General, Ken Paxton. The law, which was slated to go into effect on January 1, 2026, would have imposed onerous age assurance and parental consent obligations on app stores and app developers, which our expert panelists analyzed in depth in a webinar last month (and which we detailed in a FAQ).Continue Reading Federal Judge Enjoins Enforcement of Texas App Store Age Verification Law

The 2025 legislative cycle marked a pivotal year in US privacy law, defined not only by continued nationwide expansion into Artificial Intelligence (AI) governance, children’s and teen privacy and online safety, as well as emerging data categories, but by a major restructuring of California’s privacy enforcement infrastructure. California’s introduction of the Delete Request and Opt-out Platform (DROP) system, the nation’s first centralized, statewide platform for managing consumer deletion requests; combined with sweeping reforms to the Consumer Privacy Fund, will materially increase CalPrivacy and attorney general enforcement capacity on a recurring, self-replenishing basis. These developments accompany completion of a far-reaching rulemaking package that imposes detailed obligations for Data Protection Impact Assessments (DPIAs or risk assessments), cybersecurity governance and Automated Decision-Making Technology (ADMT). At the same time, states beyond California have enacted targeted statutory reforms addressing neurotechnology, data-broker practices and minors’ online safety, underscoring that – absent federal preemption – state-driven models will continue to shape the national privacy compliance landscape in 2026. By January 2026, there will be 20 state consumer privacy laws in effect, several with unique material obligations. We detail what enterprises need to be prepared for in 2026 and explain why we believe next year will be a watershed period for consumer privacy in the US.Continue Reading 2025 State Privacy Roundup: Key Trends and California Developments to Watch in 2026

On November 13, 2025, the Government of India formally brought into effect the much-awaited Digital Personal Data Protection Rules, 2025 (Rules). The Rules enforce the Digital Personal Data Protection Act, 2023 (DPDP Act) and provide practical guidance on how to comply with certain provisions of the DPDP Act. Together, they implement binding legislation that regulates the management of digital personal data[1] in and from India.Continue Reading India Passes the Digital Personal Data Protection Rules, Ushering in a New Digital Age in India 

On September 25, the California Privacy Protection Agency (CPPA) Board advanced OAL-approved updates to the California Consumer Privacy Act (CCPA), the process of which we covered in detail here and here, that include long-awaited regulations on cybersecurity audits, risk assessments, and automated decision-making technology (ADMT). The CPPA Board also approved a $1.35 Million settlement with Tractor Supply Company, officially announced this week. At last week’s meeting, staff reported that there were hundreds of investigations and enforcement actions in progress, many of which were at a stage that the applicable businesses were not yet aware that they are a target. 2026 will bring new privacy obligations for businesses and greater repercussions for half-baked compliance efforts.Continue Reading California Privacy Agency Rolls Out New Regulations and Approves $1.35 Million Penalty in Latest CCPA Enforcement Action

September 17, 2025, at 1:00 pm ET   

Join Julia Jacobson, Partner (New York), and Kyle Dull, Senior Associate (New York), for “Survey of U.S. Data Privacy Laws,” a Strafford Live CLE Webinar.

For more information: https://www.sp-04.com/r/products/tllspdzsna 

(We have a limited number of complimentary passes. Please contact julia.jacobson@squirepb.com by September…

Inside AI Policy reports that a survey of U.S. office workers indicates that across industries approximately half of survey respondents said that they do or would use AI contrary to company policy to make their job easier, including 42% of security sector workers.  The study published on August 20, 2025 by CalypsoAI, found that while 87% of respondents indicated that their employers had AI governance policies 52% are not prepared to follow restrictions, and 28% admitted to submitting sensitive or proprietary  data or documents so AI could complete a task; 29% used AI to generate something sent without, or with minimal, review; and 25% used AI without knowing if the use case was permissible.  The results for highly regulated industries are not better, and in some cases worse.  For instance, 60% of employees in financial services and banking indicated that they use AI tools regardless of company policy and 36% “don’t feel guilty about it.”Continue Reading Rogue AI Usage and High-risk Data Processing Runs Rampant