Connecticut Data Privacy Act (CTDPA)

Hot on the tail of California Attorney General Rob Bonta’s announcement of an investigative sweep targeting streamlining services (see our blog post here), Connecticut’s Office of the Attorney General (“OAG”) is making headlines with its recent report covering its preliminary enforcement actions under the Connecticut Data Privacy Act (“CTDPA”). We’ve previously covered Colorado and California enforcement activity here.Continue Reading Connecticut Attorney General Report: CTDPA Enforcement Insights & Takeaways

2023 was an eventful year for privacy legislation, regulation and regulatory enforcement. The compliance landscape continues to develop and evolve rapidly, making it difficult for covered businesses to keep up with the myriad requirements. In this post, we discuss some of the year’s most interesting privacy compliance developments globally.Continue Reading 2023 Privacy Compliance Year in Review

As of July 1, four states’ privacy laws will be effective and enforceable – the California Consumer Privacy Act as amended by the California Privacy Rights Act of 2020 (CPRA) (collectively, CCPA), effective since January 1, becomes enforceable on that date; the Virginia Consumer Data Protection Act (VCDPA) has been effective and enforceable since January 1; and, on July 1, the Colorado Privacy Act (CPA) and Connecticut Data Privacy Act (CTDPA) are both effective and enforceable.

There are a number of compliance obligations that overlap among these laws where prior compliance efforts for the original CCPA in 2020, and in relation to its updates for January 1 of this year, will suffice for compliance with the other, non-California laws. This said, Colorado’s regulations, promulgated on March 15, 2023, materially deviate from the CCPA in a number of consequential areas in a way that likely requires companies to revisit their January 2023 privacy notices and practices. Now is also a good time to address CPRA, CPA, CTDPA and VCDPA compliance posture generally. While some businesses plan to wait until their end-of-year review and update process, when they can also assess the many additional state laws that have or will pass this year, delaying compliance until then risks enforcement actions, particularly by California and Colorado regulators (interestingly, Connecticut’s Attorney General recently released an FAQ).

This top-level summary of key considerations outlines the issues we are finding that clients have often overlooked in their January 2023 updates.
Continue Reading Are You July-1-READY? 2023 Privacy Laws and Regulations Call for Revisiting Your 2022 End-of-Year Compliance Efforts

On April 13, 2023, the Indiana legislature passed Senate Bill 5 (“SB 5”)—more commonly referred to as the Indiana Consumer Data Privacy Act or “Indiana CDPA”—sending the legislation to Governor Eric Holcomb’s desk for signature. Governor Holcomb has until Thursday, April 20 to act on the bill. The Indiana CDPA will become law either if the governor signs the bill or takes no action before the April 20 deadline.
Continue Reading Follow the Leader: Indiana Becomes Latest State to Enact Consumer Privacy Statute

2022 was another eventful year in the realm of privacy, security and innovation.  Privacy World was there every step of the way, to keep you informed on key developments.  Starting next week, we will be rolling out our popular Year in Review series.  As a lead up to that, below are our ten most popular…

The Interactive Advertising Bureau (IAB) and IAB Tech Lab have proposed updates their industry level agreements and privacy signal program to support the efforts of marketers, agencies, publishers, and ad tech companies to comply with the US state privacy laws going into effect in 2023. The comment period on the updates is open until October 27.
Continue Reading Ad Industry Group Modifies Its Compliance Program to Address 2023 US State Privacy Laws

This blog post is a bonus supplement to our quarterly Artificial Intelligence and Biometric Privacy Quarterly Review Newsletter. Be on the lookout for our Q3 Newsletter!

We are quickly approaching the Jan. 1, 2023 operative date of most of the provisions of the California Privacy Rights Act (“CPRA), which, as most of us know by now, substantially amends the CCPA. Under the CPRA, the California Privacy Protection Agency (“CPPA” or “Agency”) has a mandate to issue regulations on a number of specific topics. With just fewer than three months to go until January 1, regulations are not even close to being finalized.  The Agency released the first draft of proposed regulations on May 24, and the first public comment period ended on August 23. In a meeting held by the CPPA on Friday, September 23, the Agency gave no concrete sense of timing or any comments on topics, such as those discussed in this post, for which regulations have not even been issued. This has left many businesses feeling left in the lurch, uncertain of what to do.
Continue Reading Profiling and Automated Decision-Making: How to Prepare in the Absence of Draft CPRA Regulations

Kyle Fath, partner in the firm’s Data Privacy, Cybersecurity & Digital Assets group and Los Angeles Office, was appointed this month to serve on the Connecticut Data Privacy Act (CTDPA) working group by the joint standing committee of the Connecticut General Assembly.
Continue Reading Kyle Fath appointed to Connecticut Privacy Legislation Working Group