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. 
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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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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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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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September 30, 2024 Data Breach and Incident Response Data Security

2024 Breach Notification Law Update: Unique New State Obligations and Widespread New Federal Obligations

 Amid intense focus on AI and a flurry of consumer privacy law updates, legislative activity has continued to change data breach notification requirements in a variety of ways. Similar to 2023, a handful of changes to generally applicable state breach notification statutes were accompanied by steady sectoral activity at the state level and significant updates at the federal level, including new obligations from both the Federal Trade Commission (FTC) and the U.S. Securities and Exchange Commission (SEC). View blog post
Cellphone Privacy Security
September 25, 2024 Data Security

Cybersecurity for Lawyers: The NIST Cybersecurity Framework as a Tool and Reference

 In this post in our series on basic cybersecurity concepts for lawyers, we delve into the National Institute of Standards and Technology (NIST) Cybersecurity Framework (CSF) 2.0. View blog post
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August 30, 2024 Data Security

Cybersecurity for Lawyers: Open-Source Software Supply Chain Attacks

In this post in our series on basic cybersecurity concepts for lawyers, we address open-source software (OSS) supply chain risk. 

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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
Computer Lock Security
May 22, 2024 Data Security

Clarifying Guidance on Abundance-of-Caution Disclosures under SEC Cybersecurity Rule

 The Director of the U.S. Securities and Exchange Commission (SEC) Division of Corporation Finance issued a statement clarifying public companies' obligations to disclose cybersecurity incidents under Item 1.05 of Form 8-K. View blog post
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September 19, 2023 Data Security Data Breach and Incident Response

Updating Corporate and Cybersecurity Practices To Satisfy the SEC’s Final Cybersecurity Disclosure Rules: Assessing Materiality of Cybersecurity Incidents

 In the wake of the SEC's new rule requiring prompt disclosure of cybersecurity incidents, incident response (IR) teams have asked how they should modify IR plans to promote compliance with the new rule. View blog post
Cellphone Privacy Security
September 11, 2023 Data Security Data Breach and Incident Response

A Deep Dive Into the SEC’s Materiality Trigger for Cybersecurity Incident Disclosures

The U.S. Securities and Exchange Commission (SEC) adopted final rules relating to cybersecurity disclosure on July 26, 2023, which will take effect on December 18, 2023. 

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