In efforts to address the spread of the coronavirus in the European Union, employers and public health authorities, among others, have been processing an increased volume of personal data. In response to this, data regulators from some member states have released guidance on how to collect, share, and use personal data, especially health data, in
The Safeguards Rule of the Gramm-Leach-Bliley Act of 1999 requires financial institutions to implement security programs in order to keep customer information secure. The Safeguards Rule also extends contractually to affiliates and/or service providers of those financial institutions, including possibly “finders” (i.e., entities charging a fee to connect consumers looking for loans to lenders).
As
In many of the settlement agreements and stipulated orders in the FTC’s recently released 2019 Privacy and Data Security Update, the FTC repeatedly imposed a set of uniform mandates for businesses to implement following a data breach. Businesses subject to the new California Consumer Privacy Act may be able to use this mandate to
On February 27, 2020, the United States Court of Appeals for the Ninth Circuit issued its decision in Ramirez v. TransUnion LLC, a class-action case watched closely by consumer reporting agencies and other persons regulated by the Fair Credit Reporting Act (“FCRA”). In Ramirez, the Court held for the first time that all
Sen. Kristen Gillibrand (D-N.Y.) recently introduced a 41-page bill that would transfer the authority to create and enforce data protection rules from the Federal Trade Commission to a new independent federal agency. This proposal comes on the heels of a similar proposal from Sen. Josh Hawley (R-Mo.). Both of these proposals have emerged due to
2019 was a transformative year for the consumer financial services world. As we navigate an unprecedented volume of industry regulation, Troutman Sanders is uniquely positioned to help its clients find successful resolutions and stay ahead of the compliance curve.
In this report, we share developments on consumer class actions, background screening, bankruptcy, consumer credit
On Feb. 3, plaintiff Bernadette Barnes filed a class action lawsuit hoping to be the first case to rely on the new California Consumer Privacy Act (CCPA). The complaint was filed over a data breach that allegedly occurred before the CCPA’s Jan. 1, 2020, effective date.
Given this timing, this case will not test the
On October 11, 2019, California Governor Gavin Newsom signed into law a bill requiring “data brokers” to register with, and provide certain information to, the California Attorney General on or before January 31st following each year in which a business meets the definition of a data broker. A “data broker” means a “business that knowingly
Today, January 28, 2020, is Data Privacy Day – a day dedicated to promoting privacy and data protection best practices. In recognition of the day, Troutman Sanders attorneys have returned again this year to send a bit of data privacy cheer.
All the presents have been opened.
The New Year’s Eve ball has been dropped.