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Posts published in “Data Privacy and Security”

FTC: Businesses of All Types Subject to Safeguards Rule

Determining whether your business engages in activities that can trigger coverage is discussed by the Federal Trade Commission in just released guidance entitled “FTC Safeguards Rule: What Your Business Needs to Know.” The Rule applies to many businesses beyond the scope of what are commonly understood to be “financial institutions” and has implications for service providers to covered entities.

9th Cir. Denies Plaintiffs’ Remand Motion, Holds FCRA ‘Informational and Privacy Interests’ Sufficient for Standing

The U.S. Court of Appeals for the Ninth Circuit recently affirmed the trial court's denial of a motion for a remand to state court and the dismissal of the plaintiffs' class action suit alleging violations of the federal Fair Credit Reporting Act by a credit reporting agency. 

Fifth State in the Union Becomes Fifth State to Enact Data Privacy Legislation

On May 10, Gov. Ned Lamont signed into law Substitute Senate Bill 6 (Public Act 22-15), Connecticut’s version of comprehensive consumer data privacy legislation.  This makes Connecticut the fifth state to enact such legislation, following California, Virginia, Colorado, and Utah.  The Act will go into effect July 1, 2023.

State Privacy Legislation Update: What Happened in March, What’s Ahead, and What’s Dead

There remain over 30 comprehensive consumer data privacy bills pending in the states, but some are falling off the chart as the legislative sessions come to an end.  While the number of active bills is decreasing, there is one new state data privacy law, and others that continue to show movement. 

Amendments to the GLBA Safeguards Rule: What’s New, What’s Not, and What’s Hot for Non-Banking Financial Institutions

The Federal Trade Commission recently amended the Safeguards Rule, 16 C.F.R. § 314.1, et seq., with significant changes to how an information security program should be designed, what it must include, and who needs to be in charge.