The California Privacy Protection Agency (the “Agency” or CPPA), the new California state agency created under the California Privacy Rights Act of 2020 (CPRA) to oversee and enforce the California Consumer Privacy Act (CCPA) and the CPRA, has recently called for preliminary public comments on a proposed rulemaking under the CPRA. See the invitation from
sensitive personal information
China Promulgates Personal Information Protection Law
On Aug. 20, 2021, after two rounds of public comments on China’s draft Personal Information Protection Law (PIPL), China promulgated the final version of the PIPL, which takes effect Nov. 1, 2021. Together, the PIPL, Cybersecurity Law (which came into force June 1, 2017) and Data Security Law (which came into…
UPDATED FOR COLORADO: What is considered sensitive personal information?
Some privacy statutes explicitly reference “sensitive” or “special” categories of personal information. While such terms, when used, often include similar data types that are generally considered as raising greater privacy risks to data subjects if disclosed, the exact categories that fall under those rubrics differ between and among statutes. Furthermore, other privacy statutes do not…
Sept. 15 CLE Program: What Is Considered Sensitive Personal Information?
On Sept. 15, join GT Data, Privacy & Cybersecurity Shareholder David Zetoony and Associate Karin Ross for their myLawCLE presentation, “What Is Considered Sensitive Personal Information?”, co-sponsored with the Federal Bar Association.
The term “sensitive personal information” is often referred to in contracts, regulatory guidance, and policy documents. What constitutes sensitive personal information,…
What is considered sensitive personal information?
Some privacy statutes explicitly reference “sensitive” or “special” categories of personal information. While such terms, when used, often include similar data types that are generally considered as raising greater privacy risks to data subjects if disclosed, the exact categories that fall under those rubrics differ between and among statutes. Furthermore, other privacy statutes do not…
What is considered sensitive personal information?
Some privacy statutes explicitly reference “sensitive” or “special” categories of personal information. While such terms, when used, often include similar data types that are generally considered as raising greater privacy risks to data subjects if disclosed, the exact categories that fall under those rubrics differ between and among statutes. Furthermore, other privacy statutes do not…
Is an accountant a processor or controller under the GDPR?
A controller refers to the entity that determines the “purpose and means” of how personal data will be processed. Determining the “purpose” of processing refers to deciding why information will be processed. Determining the “means” of processing refers to deciding how information will be processed.[1] That does not necessarily mean, however, that a controller…
Can a processor decide how long data should be stored?
A controller refers to the entity that determines the “purposes and means” of how personal data will be processed. [1] Determining the “means” of processing refers to deciding “how” information will be processed.[2] That does not mean, however, that a controller must make every decision with respect to the processing of information.
The European…
Information Transparency and Personal Data Control Act Introduced in Congress
On March 10, 2021, Rep. Suzan DelBene (D-Wash.) introduced the first comprehensive consumer privacy bill of the 117th Congress. The Information Transparency and Personal Data Control Act is designed to “establish a uniform set of rights for consumers and create one set of rules for businesses to operate in,” according to a press release from…
Does inadvertent disclosure of personal data require notification under the GDPR?
Maybe not. The European Data Protection Board (EDPB) issued draft practical guidance on various types of data breaches to assist companies with identifying situations in which a data security incident may need to be reported to EU supervisory authorities (the government regulator for privacy in various EU member countries).
The EDPB addresses a very common…