The wave of online safety regulation is continuing to surge, with Brazil’s recent enactment of Law No. 15,211/2025—the Digital Statute for Children and Adolescents (Digital ECA)—as the latest addition. 

The Federal Trade Commission and Utah Attorney General recently announced a settlement with Aylo Group Ltd.

Congress included in the appropriations bill of November 12, 2025, an extension of the Cybersecurity Information Sharing Act of 2015 (CISA 2015), 6 U.S.C. §§ 1501–10, through January 30, 2026. 

The U.S. Department of Justice (DOJ) “Data Security Program” (DSP), also known as the “Sensitive Data Rule” or “Bulk Data Rule,” has prompted numerous questions about its scope and application. 

California’s legislature has once again taken center stage in the national privacy conversation, passing a flurry of privacy bills during a marathon session that stretched into the night of September 12. 

With 2025 more than half over and many state legislatures adjourned for the year, we look back at significant legislative developments concerning state comprehensive consumer privacy laws. 

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.

The TAKE IT DOWN Act (the Act), enacted on May 19, 2025, is a powerful (and controversial) new tool designed to stop people from sharing “nonconsensual intimate imagery,” or NCII, online.

In May 2025, Montana enacted Senate Bill 163 (SB 163), amending that state’s Genetic Information Privacy Act (MGIPA) to include protections for neurotechnology data—namely, data collected from the activity of the central or peripheral nervous system.

Can a communications provider be held liable when it reports to the National Center for Missing and Exploited Children (NCMEC) an image the provider believes to be child sexual abuse material based on signals provided by NCMEC? 

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

U.S. privacy law continued to expand in 2024, both geographically and substantively.  We now have 19 states with comprehensive consumer privacy laws (some of which are already in effect, while others become effective in 2025 and 2026). This recap focuses on the 10 state laws that were enacted or took effect this year, as well as the states that enacted meaningful updates.

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.