On July 30, 2024, the New York Attorney General Letitia James announced she had completed an investigation into the tracking technology practices of popular websites, and used this to create website privacy guides on online tracking for New York businesses and consumers. These consist of a “Business Guide” and a “Consumer Guide.” The Business Guide […]
NYDFS Issues Final Circular Letter Guidance on Use of AI in Insurance Underwriting and Pricing
On July 11, 2024, the New York Department of Financial Services (“NYDFS”) released Insurance Circular Letter No. 7, which establishes guidelines on the use of artificial intelligence systems (“AIS”) and external consumer data and information sources (“ECDIS”) in insurance underwriting and pricing (“Final Circular Letter”). The Final Circular Letter comes in the wake of a […]
CISA and JCDC Conduct First-Ever Public-Private AI Security Incident Tabletop Exercise
On June 13, 2024, the Cybersecurity and Infrastructure Security Agency (CISA) collaborated with the Joint Cyber Defense Collaborative (JCDC) to hold the federal government’s first tabletop exercise for “AI security incidents. JCDC led the exercise and, true to JCDC’s public-private partnership model, included over 50 participants from various government agencies and private-sector companies. For those […]
Article: White Paper on Clarifying Definitions in the Protecting Americans’ Data from Foreign Adversaries Act of 2024
Peter Swire, Senior Counsel at Alston & Bird, has published a white paper at the Cross-Border Data Forum (“CBDF”), analyzing the definitions in the Protecting Americans’ Data from Foreign Adversaries Act of 2024 (“PADFAA”), which was passed on April 24, 2024 and will take effect on June 23, 2024. The white paper discusses some ambiguities […]
Data Breach Notification Requirements under the Safeguards Rule Now in Effect
For years, the Gramm-Leach-Bliley Act (GLBA) has required financial institutions to maintain reasonable safeguards for consumer data, but has only had limited breach-reporting requirements. To the extent financial institutions were subject to breach-reporting obligations, these were set by non-GLBA legislation, such as state law, or by relatively narrow incident-reporting rules under Interagency Guidelines overseen by […]