On September 20, 2022, the Securities and Exchange Commission (SEC) settled an enforcement action with a large, registered investment adviser (the Firm) for alleged violations of the Safeguards Rule and the Disposal Rule of Regulation S-P that arose in the context of a data disposal process, imposing a $35 million penalty. Specifically, the SEC […]
Privacy
Sephora Ordered to “Make-Up” for CCPA Violations
On August 24, 2022, California Attorney General Rob Bonta announced a $1.2 million dollar settlement with Sephora to account for alleged violations of the California Consumer Privacy Act (CCPA). This is the first CCPA enforcement action taken by the California AG that has resulted in a fine and settlement. The Attorney General’s Complaint alleged Sephora […]
FTC Issues Advance Notice of Proposed Rulemaking on Commercial Surveillance and Data Security
On August 22, 2022, the Federal Trade Commission (FTC) published its advance notice of proposed rulemaking (ANPR) to request public comment on commercial surveillance and data security practices. The ANPR comes at the same time as Congress is considering the federal American Data Privacy and Protection Act (ADPPA). The FTC seeks public comment on a […]
UK Information Commissioner’s Office Issues Warning on Ransomware Payments
On July 8, 2022, the UK Information Commissioner’s Office (UK ICO) together with the UK National Cyber Security Centre (NCSC), published a joint letter asking the Law Society of England & Wales to remind its members that they should not advise clients to pay ransomware demands should they fall victim to a cyber-attack. The Law […]
California Privacy Protection Agency Initiates Notice and Comment Period for CCPA Regulations
The California Privacy Protection Agency (the “CPPA”) has issued a Notice of Proposed Rulemaking, as anticipated, for amendments to regulations the California Attorney General promulgated in 2020, and to propose new regulations under the CPPA’s mandate provided in the California Privacy Rights Act. The comment period closes on August 23, 2022. There will be a […]