Perkins Coie partner Janis Kestenbaum says the FTC is keeping the pressure on strong consumer protection enforcement despite the Trump administration’s deregulatory agenda.

Going into the Friday, April 4, 2025, meeting, the CPPA seemed poised to move forward far-reaching privacy regulations on RAs, cybersecurity audits, and ADMT.

As we close out the first quarter of 2025, one thing is unmistakable: California’s regulatory efforts continue to center on data brokers. 

The Federal Trade Commission announced long-awaited amendments to the Children’s Online Privacy Protection Act Rule on January 16, 2025, marking the first changes to the COPPA Rule since 2013. The amendments are the output of a rule review process that began in 2019 and a notice of proposed rulemaking announced in December 2023.

This year saw significant enforcement activity from the Federal Trade Commission on privacy, data security, and related technology topics, particularly with respect to location information, health, and other sensitive data; data brokers; children’s privacy and online safety; and consumer protection issues related to artificial intelligence. State-level privacy enforcers, such as those in T

Continued cyberthreats drove expanded data security and breach notification requirements in 2024. Although sectors deemed high-risk saw significant activity, we also saw proposed regulations that stand to have a significant impact on a wide swath of private companies in the year to come.

This Update outlines highlights of data security law in 2024.

CISA has proposed security requirements for certain categories of restricted data transfers. Any U.S. business that transfers its data outside the United States or gives businesses or people outside the United States access to its data should review and work with security and legal professionals to ensure compliance.

After much anticipation, on November 8, the California Privacy Protection Agency (CPPA) Board voted to advance proposed regulations for insurance, cybersecurity audits, risk assessments, and automated decision-making technology (ADMT) to formal rulemaking.