Greenberg Traurig Data Privacy & Cybersecurity attorneys Gretchen Ramos, Darren Abernethy, and Zachary Schapiro will present the CLE webinar, “U.S. Consumer Health Data Privacy Laws in 2024: Washington’s My Health My Data Act and Related State and Federal Developments,” Tuesday, Feb. 27, 2024. State legislatures and the Federal Trade Commission have begun

On Oct. 19, 2023, the CFPB released a proposed rule that, if finalized in its present form, would require covered financial institutions to provide consumers and authorized third parties with access and portability options for their financial data. The CFPB’s proposed rule, called the “Personal Financial Data Rights” rule, would implement Section 1033 of Title

Not necessarily. 

Under the GDPR, controllers are required to provide information relating to what personal data they process, and how that processing takes place. 

If the personal data the organization includes in AI prompts has been collected directly from individuals, those individuals should be provided with a copy of the organization’s privacy notice “at the

Under the GDPR, controllers are required to provide individuals with information relating to what personal data is processed, and how that processing takes place. Some supervisory authorities have specifically taken the position that organizations which use personal data to train an artificial intelligence (AI) must draft and publish a privacy notice that provides “data subjects

Data is typically needed to train and fine-tune modern artificial intelligence (AI) models. AI can use data—including personal information—to recognize patterns and predict results.

The GDPR permits controllers to process personal information if one (or more) of the following six lawful processing purposes applies:[1]

  1. Consent. A company may process personal information if it collects

When Implementing New Privacy Requirements, Don’t Forget User Perception

Recent events involving famous podcaster and comedian Joe Rogan and fitness device company Polar are a lesson in the delicate balancing act businesses face between privacy compliance and a positive user experience.

Joe Rogan screengrab of Polar Private Notice and Temporary Account Lock

A Backdrop of New Privacy Norms

Considering new and stringent privacy regulations, companies are

Most modern U.S. 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 that is available on the internet

Probably not.

Under the European GDPR, if the personal information that an organization is going to use as part of training an AI has been collected directly from individuals, then those individuals should be provided with a copy of the organization’s privacy notice “at the time when personal data are obtained.”[1] If the personal

Categorizing data as “sensitive” is a common feature in U.S. state privacy law, as well as the EU’s GDPR (which uses the term “special category” for similar personal data).[1] What is considered sensitive data varies from state to state, as well as the obligations that come with it. Colorado, Connecticut, Florida, Indiana, Montana, Oregon