Perkins on Privacy
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Perkins on Privacy

Perkins on Privacy keeps you informed about the latest developments in privacy and data security law. Our insights are provided by Perkins Coie's Privacy & Security practice, recognized by Chambers as a leading firm in the field. 
Cellphone Privacy Security
December 13, 2024 Privacy Law Recap Data Security CCPA

Privacy Law Recap 2024: Data Security

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.

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Computer Lock Security
December 11, 2024 Regulatory Enforcement Federal Trade Commission

FTC Staff Paper Finds that Most Surveyed “Smart” Products Fail to Disclose Duration of Support

 On November 26, 2024, the FTC released a staff paper regarding the disclosure of the duration of the support for the software of connected consumer devices. As the FTC staff explained, if a manufacturer stops providing software updates, products may lose their “smart” functionality, become insecure, or stop working entirely. Against that backdrop, the FTC examined the software support disclosures of manufacturers of 184 connected consumer products. The FTC concluded that just under 89% of the product web pages for the studied devices did not disclose a software support period. View blog post
Security
December 4, 2024 Privacy Compliance New Administration Regulatory Enforcement Federal Trade Commission

How the FTC’s Approach to Privacy, Security, and AI Enforcement May Change

 The new administration is likely to have a significant impact on the Federal Trade Commission’s (FTC’s) approach to privacy, data security, and other technology-related aspects of consumer protection, including artificial intelligence (AI). View blog post
World Cybersecurity
November 26, 2024 CCPA Privacy Compliance State Privacy Laws Artificial Intelligence Data Security

Fasten Your Seatbelts: CPPA Proposes Rules on Automated Decision-Making and Cybersecurity Audits and Finalizes Data Broker Regulations

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. 

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bell on front desk at hotel
November 7, 2024 Regulatory Enforcement Data Security Data Breach and Incident Response Federal Trade Commission

FTC and State Coalition Settle Data Breach Cases with Marriott

 In 2018, Marriott announced a data breach affecting its Starwood reservation system, thought at the time to have affected up to 500 million people worldwide. These settlements arise from that incident, as well as two smaller incidents that also affected Starwood and Marriott. The FTC alleges these incidents exposed payment card information, unencrypted passport numbers, and loyalty account information, along with other information like names, dates of birth, and contact information. View blog post
Happy family together at home.
August 14, 2024 Data Security Regulatory Enforcement Children’s Privacy Federal Trade Commission

FTC Order Bans Anonymous Messaging App from Serving Minors

 The Federal Trade Commission (FTC) and the Los Angeles County District Attorney announced a complaint and proposed stipulated order concerning the “NGL: ask me anything” anonymous messaging app. View blog post
Conference group
July 25, 2024 CCPA Regulatory Enforcement Artificial Intelligence

CPPA Regulatory Delays and Enforcement Updates: Takeaways from July Board Meeting

 On July 16, the California Privacy Protection Agency (CPPA) held a public meeting of its Board (the Board). View blog post
Workplace Meeting
April 10, 2024 CCPA Privacy Compliance

CPPA Board Updates Timing for Regulations, and Enforcement Division Releases Enforcement Advisory: Focus on Data Minimization!

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

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Financial Services & Investments
March 18, 2024 Regulatory Enforcement Federal Trade Commission

FTC Obtains $16.5M from Avast for Sale of Sensitive Data

The FTC's action against Avast reflects its continued focus on the mass collection and sale of sensitive personal data for advertising purposes.

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Computer server room
January 26, 2024 Regulatory Enforcement Federal Trade Commission

The FTC Continues its Focus on Location and Sensitive Data

 The Federal Trade Commission (FTC) followed its recent spate of enforcement in the location and sensitive data space with the announcement of another enforcement action and proposed settlement with InMarket Media, Inc. (InMarket). View blog post
pages of a book
August 4, 2023 Regulatory Enforcement CCPA

Full Steam Ahead: Updates in Enforcement of California Privacy Law

 A court-ordered stay on enforcement of updates to certain parts of the California privacy regulation (the Ruling) has not slowed down enforcement of the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA). View blog post
U.S. Capitol at sunset
August 1, 2023 Children’s Privacy Federal Trade Commission Regulatory Enforcement

COPPA: Public Comment Period Open for Proposed Verifiable Parental Consent Method

For the first time since 2015, the Federal Trade Commission (FTC) has been asked to approve a new "verifiable parental consent" (VPC) method under the Children's Online Privacy Protection (COPPA) Rule. 

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