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Daniel Felz

China Releases Updated Regulations on Permits Needed for Transferring Data out of China

April 2, 2024 By Daniel Felz and Yin Tydir

On March 22, 2024, the Cyberspace Administration of China (CAC) published the Regulations on Promoting and Regulating Cross-border Data Flow (the “Regulations”), effective immediately. The Regulations supplement China data protection laws (the Cybersecurity Law, the Data Security Law, and the Personal Information Protection Law), and take precedence over previously-issued data transfer rules, such as (a) […]

Filed Under: China, Data Protection, International, Regulation, Transfers Tagged With: Cross-border, International Data Transfers

More Guidance from HHS on Online Tracking Technologies but Questions Remain

March 20, 2024 By Daniel Felz, David Keating and Sara Pullen Guercio

Health and Human Services (“HHS”) released updated guidance yesterday on the use of online tracking technologies (like cookies, pixels, software development kits (SDKs), etc.) by HIPAA Covered Entities (the “Updated Guidance”). The Updated Guidance amends and supersedes HHS’s original guidance on the use of digital tracking technologies published on December 1, 2022 (the “Prior Guidance”).  […]

Filed Under: Data Breach, Data Breach Litigation, Data Security, Enforcement, ePrivacy, Health Privacy, HHS, Mobile Privacy, Online Privacy, Privacy, Privacy Litigation, Regulation

Article: Executive Order to Limit Sales of Americans’ Sensitive Data to Adversarial Foreign Governments

February 29, 2024 By Santi Villar and Daniel Felz

Peter Swire, Senior Counsel at Alston & Bird, has co-authored a detailed article in Lawfare, “Limiting Data Broker Sales in the Name of U.S. National Security: Questions on Substance and Messaging,” analyzing the Biden Administration’s new Executive Order issued yesterday. Swire’s article summarizes key aspects and impacts of the Executive Order, which is intended to […]

Filed Under: International, National Security, Transfers Tagged With: Executive Order, International Data Transfers, National Security

White House Executive Order to Regulate Transactions Involving Sensitive Personal Data of Americans

February 28, 2024 By Daniel Felz, David Keating, Jason Waite and John Lesko

Today, the White House announced that President Biden will sign an executive order designed to protect sensitive data of U.S. persons from exploitation by identified countries of concern.  This executive order is expected to be published later today, and to direct the Department of Justice (DOJ) to issue regulations designed to address transactions that involve […]

Filed Under: Data Security Tagged With: Data Transfer

NYDFS Releases Circular Letter on Use of AI in Insurance Underwriting and Pricing

February 1, 2024 By Kim Peretti, Daniel Felz, Lance Taubin and Colton Jackson

On January 17, 2024, the New York State Department of Financial Services (“NYDFS”) issued a proposed circular letter for comment regarding the “Use of Artificial Intelligence Systems and External Consumer Data and Information Sources in Insurance Underwriting and Pricing” (the “Circular Letter”). The Circular Letter details NYDFS’ expectations and guidelines for the use of artificial […]

Filed Under: AI, Artificial Intelligence, Regulation Tagged With: AI, Artificial Intelligence, Insurance, National Institute for Standards and Technology (NIST), NYDFS

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