On March 29, 2024, the Federal Trade Commission (the “FTC”) published a unanimous decision to deny an application by the Entertainment Software Rating Board, Yoti, and SuperAwesome (collectively, the “Applicants”) to add a new verifiable parental consent (“VPC”) mechanism under the Children’s Online Privacy Protection Rule (“COPPA Rule”). The application, which our previous blog post […]
Board Governance & Cyber Risk Management
China Releases Updated Regulations on Permits Needed for Transferring Data out of China
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) […]
More Guidance from HHS on Online Tracking Technologies but Questions Remain
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”). […]
State AGs and Other Stakeholders Weigh In On Proposed COPPA Rule Update
The Federal Trade Commission (FTC) received over 270 comments to its notice of proposed rulemaking (NPRM) for the amendments to the Children’s Online Privacy Protection Rule (COPPA Rule) during the public comment period that ended on March 11, 2024. The NPRM reflects the FTC’s continued effort to modernize the COPPA Rule, which implements the Children’s […]
White House Executive Order to Regulate Transactions Involving Sensitive Personal Data of Americans
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 […]