In October 2018, the Federal Trade Commission (“FTC”) published a report that summarized discussions at a December 2017 workshop discussing the potential impact to consumers of privacy and security incidents. The purpose of the workshop was to explore whether government intervention in this arena is warranted under the enforcement authority granted to the FTC under […]
Privacy
Alston & Bird Issues Advisory on Applying GDPR Experience to CCPA Implementation
Alston & Bird recently issued an advisory entitled, “Applying GDPR Process Lessons to the CCPA,” authored by Jim Harvey and Karen Sanzaro. The recently and hastily adopted California Consumer Privacy Act of 2018 (CCPA) has already been compared to the General Data Protection Act (GDPR), though the two greatly differ in scope and content. However, […]
Governor Jerry Brown Signs Amendment to the California Consumer Privacy Act
On September 23, 2018, Governor Jerry Brown signed SB 1121, the amendment to the California Consumer Privacy Act (CCPA). SB 1121 attempts to clean up some drafting errors and ambiguities in the original legislation (AB 375), but it also effectively reduces the procedural obstacles to the CCPA’s private right of action by removing the requirement […]
An Update on the California Consumer Privacy Act and Its Private Right of Action
While it remains to be seen what the final text of the California Consumer Privacy Act (CCPA) looks like when it is ultimately implemented on January 1, 2020, at present it seems likely that businesses and employers can expect an influx of lawsuits from individual consumers proceeding under the CCPA’s private right of action. Under […]
CFPB Changes Annual Notice Requirement Under Reg. P
On Friday, the Consumer Financial Protection Bureau announced its “finalized amendments” to Regulation P, an implementing regulation of the federal financial Gramm Leach Bliley Act. Regulation P governs the provision of privacy notices for covered financial institutions. In response to legislation passed by Congress in late 2015, the final rule issued Friday permits financial institutions […]