In late August 2023, the California Privacy Protection Agency (“CPPA” or “Agency”) released a discussion draft of proposed regulations under California’s data privacy law, the California Consumer Privacy Act (“CCPA”). Importantly, the proposed regulations set forth more detailed obligations for company cybersecurity programs, including routinely assessing and filing audits with the CPPA. Though these draft […]
Data Security
NIST Cybersecurity Framework 2.0 Released for Public Comment
On August 8, 2023, the National Institute of Standards and Technology (NIST) released the initial draft of its Cybersecurity Framework 2.0 and draft Implementation Examples for public comment. This marks the first significant update to the NIST Cybersecurity Framework (“Framework”) since its initial release in 2014, which is intended to address current and future cybersecurity […]
FTC Launches Investigation into Creator of ChatGPT
In mid-July, the Federal Trade Commission (FTC) reportedly opened an investigation into OpenAI, the maker of ChatGPT, sending the company an extensive Civil Investigative Demand (CID). While FTC investigations are normally non-public, the Washington Post published what appears to be part of the CID sent from the FTC to OpenAI. This investigation comes on the […]
Chinese Hackers Exploit Gap in Cloud Environment Used by U.S. Government
According to recent reports issued by Microsoft and U.S. government agencies, hackers recently exploited a gap in Microsoft’s cloud environment, enabling the malicious actors to access the email accounts of employees at the United States Commerce and State Departments. Including the U.S. government, around 10 organizations were victimized in the U.S. and about 25 were […]
International Data Transfers: Lessons from the EDPB’s “101 Task Force”
In August 2020, privacy activist organization NOYB – European Center for Digital Rights filed 101 complaints with the EU Supervisory Authorities (‘SAs’) in connection with the transfer of personal data from Europe to the U.S., by companies that had implemented “Google Analytics” and “Facebook Business Tools” on their websites. Following these complaints, the European Data […]