On July 8, 2022, the California Privacy Protection Agency (“CPPA”) released proposed regulations to implement the California Privacy Rights Act (“CPRA”). The new proposals would dramatically change the existing regulations that apply to organizations that do business in California.
Click here to read the full article, published by the Washington Legal Foundation Aug. 19, 2022.
On Aug. 11, 2022, the U.S. Consumer Financial Protection Bureau issued guidance indicating that financial institutions and service providers that fail to adopt sufficient data security measures to protect consumer financial data may violate the Consumer Financial Protection Act provision prohibiting unfair acts and practices.
On Aug. 8, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) imposed economic sanctions on Tornado Cash, a popular cryptocurrency mixing service that allows customers to obscure the original source of virtual currency transactions by “mixing” multiple transactions and then redistributing them. While mixing may have legitimate benefits in some transactions,
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 |
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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 |
 |
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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 |
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On June 24, 2022, China’s National Information Security Standardization Technical Committee (commonly referred to as “TC260”) finalized the Technical Guideline on Personal Information Cross-Border Transfer Certification (Final Cert Guideline). Although the Final Cert Guideline largely remains the same as the draft version released this past April, which is described in our prior blog post, China
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