Most businesses are already familiar with the Fair Credit Reporting Act (“FCRA”) and the various requirements to protect the fairness, accuracy, and privacy of consumer credit information. However, a recent FTC enforcement action against the retailer Kohl’s Department Store, Inc. (“Kohl’s”) has brought a rarely used provision of the statute to light. This provision—codified […]
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Proposed Federal Privacy Legislation Tackles COVID-19 Data
Data collection and analysis is becoming a key weapon in the fight against COVID-19 both here in the United States and around the globe. But as governments and tech companies roll out a variety of applications and contact tracing tools, legislators from both sides of the political aisle are questioning how to handle the data […]
COVID-19 Is Not A Free Pass For Privacy And Security Compliance
In the wake of stay-at-home orders stemming from the COVID-19 pandemic, companies have rushed to provide work-from-home options for many, if not all, of their employees. As exigency fades into the new normal, however, the California Attorney General and New York’s Department of Financial Services (NYDFS) – two key privacy and security regulators – have […]
Location and Mobile Data in the Fight against COVID-19 – An Overview of U.S. and Global Efforts
Governments are increasingly seeking to leverage consumer geolocation and other mobile device data to assist with fighting the spread of COVID-19, as cases continue to mount globally. Location data can be of significant value to public health models, such as models that determine areas where social-distancing measures are needed or test whether such measures are […]
DOJ Releases Guidance On Gathering Threat Intel From The Dark Web
The Cybersecurity Unit (“CsU”) of the Computer Crime and Intellectual Property Section of the Criminal Division of the United States Department of Justice (“CCIPS”) has released its guidance on “Legal Considerations when Gathering Online Cyber Threat Intelligence and Purchasing Data from Illicit Sources” (“Guidance”). The CsU prepared the Guidance—with input from the FBI, the U.S. […]