On Nov. 12, 2024, the Consumer Financial Protection Bureau (CFPB) released a report examining federal and state privacy protections for consumers’ financial data. In the report, the CFPB “critiques” the privacy protections available under the Gramm-Leach-Bliley Act (GLBA) and the Fair Credit Reporting Act (FCRA), asserting that the federal framework has “limitations.” The CFPB then
On April 27, 2023, Washington enacted the “My Health My Data Act” (WMHMDA or the Act). Unlike other modern state privacy laws that purport to regulate any collection of “personal data,” WMHMDA confers privacy protections only upon “Consumer Health Data.” While the Act was promoted as a measure to help protect reproductive and gender affirming
On April 17, 2023, the Washington State Legislature passed the “My Health My Data Act” (“WMHMDA” or “Act”). Unlike other modern state privacy laws that purport to regulate any collection of “personal data,” WMHMDA confers privacy protections only upon “Consumer Health Data.” While the Act was promoted as a measure to help protect
Greenberg Traurig Shareholders Breton H. Permesly and Tyler J. Thompson will present the CLE webinar, “Personal Information in the Franchise Relationship,” on Wednesday, June 28 at 12:30 pm EDT. As privacy laws proliferate around the world while the value of customer personal information simultaneously increases, data has never been riskier or had
On April 17, 2023, the Washington State Legislature passed the “My Health My Data Act” (WMHMDA), which will take effect for most companies March 31, 2024. Unlike other modern state privacy laws that purport to regulate any collection of “personal data,” WMHMDA confers privacy protections only upon “Consumer Health Data.” This term is defined to
The CCPA states that a service provider must be contractually prohibited from “retaining, using, or disclosing the personal information [provided to it by a business] for any purpose other than for the business purposes specified in the contract for the business . . . .”[1] That prohibition, however, may not apply to information once
GT Shareholders Gretchen A. Ramos, Co-Chair of the Global Data Privacy & Cybersecurity Practice, and Darren Abernethy will present the CLE webinar, “The Final CCPA Regulations: What You Need To Know,” March 2 at 12:00 p.m. PT. The webinar will provide an overview of key takeaways from the finalized proposed
Modern data privacy statutes require that organizations inform individuals about the organization’s privacy practices by creating a privacy notice (sometimes referred to as a privacy policy or a notice at collection). Some data privacy statutes provide specific directions regarding how the privacy notice must be distributed. For example, the California Consumer Privacy Act and the
The regulations implementing the CCPA require that a business verify the identity of a consumer that submits a specific-information access request to a “reasonably high degree of certainty.”[1] The regulations provide as an example matching three pieces of personal information provided by the consumer with three pieces of personal information maintained by the business
The CCPA and its implementing regulations identify six types of information requests that a consumer can submit to a business. As the first five requests ask that a business respond with broad information about the type of information collected (as opposed to the actual information itself), they are often referred to as category-level access requests.