Enforcement of the California Consumer Privacy Act (CCPA) began July 1, 2020. Our privacy team at Troutman Pepper includes several attorneys who worked in an attorney general’s office. This privacy regulatory team has identified six areas of enforcement likely to catch the California Office of the Attorney General’s (OAG) attention, which arguably holds sole regulatory

The Federal Trade Commission (“FTC”) held its public workshop on the proposed changes to the Safeguards Rule under the Gramm-Leach-Bliley Act of 1999 (“GLBA”). The FTC has not updated the Safeguards Rule since implementing it in 2003. With substantial developments in the way businesses increasingly depend and operate using non-public personal information through electronic means

Enforcement of the California Consumer Privacy Act (CCPA) began July 1, 2020. Our privacy team at Troutman Pepper includes several attorneys who worked in an attorney general’s office. This privacy regulatory team has identified six areas of enforcement likely to catch the California Office of the Attorney General’s (OAG) attention, which arguably holds sole regulatory

The Federal Trade Commission (“FTC”) is holding its public workshop today on the proposed changes to the Gramm-Leach-Bliley Act of 1999’s Safeguards Rule (“Safeguards Rule”). For background, the Safeguards Rule requires financial institutions, and potentially affiliates and/or service providers, to keep customer information secure. The FTC has stated it seeks to modify the Safeguards Rule

On July 1, the Cybersecurity and Infrastructure Security Agency (“CISA”) launched its second installment of the “Cyber Essentials Toolkit” titled, “Your Staff, The Users.” This installment follows last month’s “Yourself, The Leader,” where CISA provided business leaders with information to better implement a culture of cyber readiness within organizations. To read more about the first

States nationwide facing the risks of the coronavirus (“COVID-19”) pandemic are attempting various approaches to fight the disease, such as through social distancing, use of facemasks, increased disinfection of surfaces, and contact tracing. Unfortunately, contact tracing appears to be an effective way not only to fight COVID-19, but also for scammers to steal personal information

Authors:
Ron Raether, Partner, Troutman Sanders
Wynter Deagle, Partner, Troutman Sanders
Sharon Klein, Partner, Pepper Hamilton
Alex Nisenbaum, Partner, Pepper Hamilton
Sadia Mirza, Associate, Troutman Sanders
Sam Hyams, Associate, Troutman Sanders

On June 24, 2020, the California Secretary of State released a memorandum (available here) stating that the California Privacy Rights Act

With all 50 states in the process of lifting stay-at-home orders, many businesses are eager to reopen but remain committed to protecting their most important assets — their employees. As part of establishing reopening procedures, some businesses have considered collecting health-related information from employees to prevent the spread of COVID-19 among the workforce.

While collecting

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A review of privacy and data breach class action lawsuits reveal an ongoing trend. Plaintiffs filing these actions, time and time again, rely on the same allegations concerning missteps taken by an organization in the areas of privacy and data security. Allegations usually range