Roughly six months since Andrew Ferguson became Chairman of the Federal Trade Commission, an FTC workshop on children’s privacy and online safety has provided a glimpse into the agency’s approach to these issues.

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.

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.

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. 

This year, the blossoming of spring is accompanied by a pair of noteworthy California Privacy Protection Agency (CPPA) updates. 

Last month, Senators Richard Blumenthal (D-Conn.) and Marsha Blackburn (R-Tenn.) reintroduced the Kids Online Safety Act (KOSA), initially introduced last term, noting that the bill now has 62 cosponsors, bipartisan support, and is poised to pass in the Senate.