Some modern data privacy statutes mandate that organizations allow third parties – who are authorized by a data subject – to submit access, deletion, correction, or other requests on behalf of a consumer. Such third parties are sometimes referred to as “authorized agents” – a term created by the regulations implementing the CCPA. The following

The following is part of Greenberg Traurig’s ongoing series analyzing cross-border data transfers in light of the new Standard Contractual Clauses approved by the European Commission in June 2021.

Controller A-1 (EEA) → Controller A-2 (Non-EEA)

Visual Description and Implications
  • Background. Company A-1 and Company A-2 are corporate affiliates that are under common ownership

The following is part of Greenberg Traurig’s ongoing series analyzing cross-border data transfers in light of the new Standard Contractual Clauses approved by the European Commission in June 2021.

Controller A (EEA)  → Controller B (EEA) → Controller C (Non-EEA)

Visual Description and Implications
  • Background. Company A in the EEA transfers personal data to

The following is part of Greenberg Traurig’s ongoing series analyzing cross-border data transfers in light of the new Standard Contractual Clauses approved by the European Commission in June 2021.

Controller A (EEA) → Controller B (EEA) → Processor Z (Non-EEA)

Visual Description and Implications
  • Background. Company A in the EEA transfers personal data to

Several modern state data privacy statutes refer to precise geolocation information as a “sensitive” category of personal information. What constitutes precise geolocation information differs slightly between and among states. The following table provides a side-by-side comparison of the how the states have defined the term.

Click here for a side-by-side comparison of the how the

Most modern state data privacy laws exempt from their definition of personal information “publicly available information.” What constitutes publicly available information differs between state privacy laws and may not correlate to the lay definition understood by many businesses and individuals. For example, while some businesses may consider information available on the internet “publicly available information

The following is part of Greenberg Traurig’s ongoing series analyzing cross-border data transfers in light of the new Standard Contractual Clauses approved by the European Commission in June 2021.

Data Subject (EEA) → Processor Z-1 (non-EEA) → Processor Z-2 (EEA) → Controller A (EEA)

Visual Description and Implications
Background. Company A retains Company Z-2

As more children spend their time online exploring and learning, government bodies in the United States and internationally have enacted policies to ensure safer spaces, privacy, security, and protection for children online. The California Senate Judiciary Committee recently voted to advance two California bills to protect children’s online activities.

Closely modeled after the UK’s Children’s

Controller A (Non-EEA) → Processor Z (Non-EEA) → Sub-processor Y (EEA) → Controller A (Non-EEA) (same country)

Visual Description and Implications
  • Transfer 1: No mechanism needed.  Company A is not required under the GDPR to put safeguards in place to transfer information to a processor that is also located in Country Q.
  • Transfer 2: No

On July 8, 2022, the California Privacy Protection Agency (CPPA) issued proposed amendments to the California Consumer Privacy Act (CCPA) regulations to harmonize them with the California Privacy Rights Act of 2020 (CPRA), which will go into effect on Jan. 1, 2023. Individuals or companies have until Aug. 23, 2022, at 5 p.m. to submit