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David Keating

Declassified Intelligence Community Letters Highlight Importance of Monitoring Outbound Data Flows

February 16, 2024 By Santi Villar and David Keating

On January 25, 2024, Senator Ron Wyden (D-OR) released documents that confirm U.S. intelligence agencies are purchasing location and other sensitive personal information from data brokers without the consent of the data subjects. The FTC has recently gone after data brokers who collect and sell the sensitive location data of consumers without their express consent, […]

Filed Under: National Security & Digital Crimes, Privacy & Cyber Regulatory Enforcement Tagged With: Government Access to Data, Location Data, Sensitive Data

Colorado AG Recognizes Global Privacy Control as the First Valid Universal Opt-Out Mechanism

January 4, 2024 By David Keating and Hyun Jai Oh

On December 29, 2023, the Colorado Attorney General (the “AG”) announced that the Global Privacy Control (“GPC”) will become the first universal opt-out mechanism (“UOOM”) the AG considers valid under the Colorado Privacy Act (the “CPA”).  Effective July 1, 2024, controllers subject to the CPA will need to treat Colorado consumers’ privacy preferences submitted through […]

Filed Under: Adtech & Digital Tracking, Board Governance & Cyber Risk Management, Privacy & Cyber Regulatory Enforcement Tagged With: Behavioral Tracking, Data Protection, Privacy, Regulatory Enforcement, Tracking, US State Law

California Attorney General Initiates New Investigative Sweep under the CCPA

January 30, 2023 By David Keating

The California Attorney General on Friday announced a new investigative sweep under the California Consumer Privacy Act (CCPA).  The announcement marks the third year in a row in which the Attorney General’s office has initiated a significant enforcement or regulatory initiative on Data Privacy Day[1].  This year, Attorney General Bonta’s team is focusing on B2C […]

Filed Under: Uncategorized

CPPA Expected Not to Meet CPRA Rulemaking Deadline

February 17, 2022 By David Keating and Dorian Simmons

At a board meeting held by the California Privacy Protection Agency (CPPA) on February 17, 2022, Executive Director Ashkan Soltani announced that the CPPA does not expect to meet the July 1, 2022, statutory deadline for adopting final regulations under the California Privacy Rights Act.  The CPPA plans to schedule meetings in March and April […]

Filed Under: Adtech & Digital Tracking, California Privacy & the CCPA, Privacy & Cyber Regulatory Enforcement Tagged With: California Privacy Protection Agency (CPPA), California Privacy Rights Act (CPRA)

CCPA Plaintiffs Testing whether Any CCPA Violation Can be Used to Bring Class Actions

April 13, 2020 By David Keating, James Harvey and Daniel Felz

Plaintiffs’  counsel  have  started  to  lay  the  groundwork  in the last few weeks for  a  broad  private  right  of action under the California Consumer Privacy Act (the “CCPA”).  Alston & Bird has published an Advisory that evaluates this recent CCPA litigation, and offers practical advice to companies as they build CCPA compliance.  In this Advisory, […]

Filed Under: Board Governance & Cyber Risk Management, California Privacy & the CCPA, Privacy & Cyber Regulatory Enforcement, Privacy & Cybersecurity Litigation Tagged With: California Consumer Privacy Act (CCPA)

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