On July 20, 2023, the Office for Civil Rights (“OCR”) of the U.S. Department of Health and Human Services (“HHS”), and the Federal Trade Commission (“FTC”) published a joint letter sent to approximately 130 hospital systems and telehealth providers. The FTC/OCR letter warns that certain online tracking technologies that “may be present” on the recipients’ […]
Data Protection
Texas Becomes Tenth State to Enact a Comprehensive State Privacy Law
On June 18, 2023, Texas Governor Greg Abbott signed the Texas Data Privacy and Security Act (HB 4) (“TDPSA”) into law, making Texas the latest contributor to the growing patchwork of comprehensive U.S. state privacy laws. TDPSA takes effect July 1, 2024, except for provisions that enable consumers to designate authorized agents to exercise on […]
NY DFS Releases Revised Proposed Second Amendment of its Cybersecurity Regulation
The New York Department of Financial Services (“NY DFS”) published an updated proposed Second Amendment to its Cybersecurity Regulation (23 NYCRR Part 500) in the New York State Register on June 28, 2023, updating its previous proposed Second Amendment, which was published November 9, 2022. While the language proposed is largely similar to the previous […]
Council of Europe Launches Model Contractual Clauses for Transfers of Personal Data
On June 16, 2023, the Council of Europe’s Committee of Convention 108+ (i.e., the Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data) adopted Model Contractual Clauses for cross-border data flows (“MCCs”). The MCCs are intended to cover the transfers of personal data to countries that are not parties to […]
Joint Regulatory Guidance Aims to Help Companies Transfer Personal Data Across ASEAN and EU Member States
On May 23, 2023, the European Commission together with ASEAN (the Association of Southeast Asian Nations) published guidance that identifies commonalities and differences between the EU Standard Contractual Clauses for international data transfers (“SCCs”), and ASEAN’s Model Contractual Clauses (“MCCs”), to assist companies with their efforts to comply with data transfer rules in both regions […]