Alston & Bird Privacy, Cyber & Data Strategy Blog

The FTC’s COPPA Policy Statement to Incentivize Age Verification Through a More Flexible Enforcement Approach

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On February 25, 2026, the Federal Trade Commission (“FTC”) issued an enforcement policy statement announcing that the Commission will not bring enforcement actions under the Children's Online Privacy Protection Act ("COPPA") Rule against operators of general audience sites and services and mixed audience sites and services that collect, use, or disclose personal information for the sole purpose of determining a user’s age without first obtaining verifiable parental consent (“VPC”). The policy … [Read more] about The FTC’s COPPA Policy Statement to Incentivize Age Verification Through a More Flexible Enforcement Approach

NYDFS Revises Prescriptive FAQs on Multifactor Authentication

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Two months after the New York Department of Financial Services (“NYDFS”) updated its Frequently Asked Questions (“FAQs”), which we wrote about here, NYDFS has released updated FAQs on multifactor authentication (“MFA”) that further clarify 23 NYCRR § … [Read more] about NYDFS Revises Prescriptive FAQs on Multifactor Authentication

Threat Actors Exploit Google’s Gemini to Accelerate Cyberattacks

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Google Threat Intelligence Group (GTIG) recently reported that cybercriminals—in particular, state-sponsored threat actors from North Korea, Iran, China, and Russia—are misusing Gemini, Google’s large language model (LLM), to support all stages of … [Read more] about Threat Actors Exploit Google’s Gemini to Accelerate Cyberattacks

CISA Revives CIRCIA Rulemaking

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Almost two years after seeking stakeholder input about a final rule under the Cyber Incident Reporting for Critical Infrastructure Act of 2022 (CIRCIA), the Cybersecurity and Infrastructure Security Agency (CISA) announced that it will hold virtual … [Read more] about CISA Revives CIRCIA Rulemaking

Genetic Goldmine or Legal Landmine? Tempus AI Confronts GIPA Exposure

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Artificial Intelligence

On February 13, 2026, a putative class filed a Complaint in the U.S. District Court for the Northern District of Illinois alleging that Tempus AI, Inc. (“Tempus AI”) violated the Illinois Genetic Information Privacy Act (410 ILCS 513/1 et seq., … [Read more] about Genetic Goldmine or Legal Landmine? Tempus AI Confronts GIPA Exposure