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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. 

Business
December 4, 2025 Regulatory Enforcement Data Security Data Breach and Incident Response

SEC Dismisses Cyber Disclosure Case Against SolarWinds and CISO

Key Takeaways

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Computer Lock Security
November 25, 2025 Children’s Privacy Online Safety Regulatory Enforcement Federal Trade Commission

The FTC and Utah Attorney General Focus on Online Safety: Takeaways for All Platforms

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

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Government Contracts, Privacy & Security
October 30, 2025 Data Security CCPA Regulatory Enforcement Privacy Compliance State Privacy Laws Data Breach and Incident Response Legislative Developments

Preparing for the California Cyber Audit Regulations

On September 23, 2025, the California Privacy Protection Agency confirmed that their cyber audit regulations will at long last go into effect on January 1, 2026. 

You can be forgiven for losing track since these were first proposed in September 2023, but now is the time to start considering how they will apply to your company and budgeting for that impact. 

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Data Center
October 15, 2025 Data Breach and Incident Response Data Security Legislative Developments

2025 Breach Notification Law Update

State Updates, Security Mandates, and the Federal Regulatory Horizon

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Court Gavel
October 10, 2025 Federal Trade Commission Regulatory Enforcement Children’s Privacy Online Safety

Lessons From the FTC’s First Privacy Enforcement Actions During Trump 2.0

The Federal Trade Commission (FTC) recently announced its first privacy enforcement actions of the second Trump administration with a flurry of activity in September. View blog post
Cellphone Privacy Security
July 22, 2025 Children’s Privacy Online Safety Federal Trade Commission Regulatory Enforcement

What to Expect from the FTC in Youth Privacy and Online Safety

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.

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Computer Lock Security
July 11, 2025 Content Moderation Online Safety ECPA

Another Take on the TAKE IT DOWN Act

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.

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woman typing on a cell phone
June 2, 2025 Content Moderation Privacy Compliance Privacy Litigation ECPA Online Safety

Can Providers Be Sued for Mistaken CSAM Reports? Maybe, Says New Ruling

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? 

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Security
May 5, 2025 Children’s Privacy Federal Trade Commission Regulatory Enforcement

FTC (Finally) Publishes Amended COPPA Rule: Compliance Deadlines Set

On April 22, 2025, the Federal Trade Commission published in the Federal Register the amendments to the Children’s Online Privacy Protection Act (COPPA) rule it announced on January 16, 2025. View blog post
privacy shield
April 25, 2025 Regulatory Enforcement Federal Trade Commission Consumer Protection

FTC Enforcement Priorities Take Shape With Resource Cuts in Mind

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

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Security
February 7, 2025 Privacy Compliance Children’s Privacy Federal Trade Commission Regulatory Enforcement

FTC Announces New Children’s Privacy Requirements in Updated COPPA Rule

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.

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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
Supreme Court
December 2, 2024 State Privacy Laws Privacy Compliance Privacy Litigation ECPA

Massachusetts Supreme Court Decision Raises Bar for Website “Wiretap” Suits

In recent months, a wave of lawsuits has swept across the nation, targeting websites for allegedly violating state wiretapping laws through their use of tracking software.

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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
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