Under a Vermont law, data brokers that process information regarding Vermont residents are now subject to registration and security requirements beginning January 1, 2019. Included in the new law are three notable components: (1) a broad statutory definition of a “data broker,” (2) an annual registration requirement for data brokers, and (3) reporting on data […]
Legislation
The CLOUD Act and its Impact on Cross-Border Access to the Contents of Communications
On Friday morning, March 23, President Trump signed the $1.3 trillion omnibus spending bill into law, including the Clarifying Lawful Overseas Use of Data (CLOUD) Act, and in doing so established a sea change in the rules for cross-border government access to the contents of electronic communications. The CLOUD Act consists of three core components: […]
German DPAs Publish Model GDPR Processing Records – Translations Provided
In just under 100 days, the EU General Data Protection Regulation (GDPR) enters into force. One of the major changes the GDPR introduces is a duty for in-scope controllers and processors to maintain written records of their processing activities. Under Article 30 GDPR, companies will need to inventory all “processing activities under [their] responsibility” and […]
ePrivacy Regulation Trilogue Negotiations Pushed back to Fall 2018; Final ePrivacy Regulation may not be in Place until 2020
About this time last January, the European Parliament released its proposal for a new ePrivacy Regulation. The intent of the ePrivacy Regulation is to replace the current ePrivacy regime – which consists of an ePrivacy Directive and a patchwork of local implementing legislation – with a uniform set of directly-applicable EU-wide rules. Since the Parliament […]
Data Protection Litigation to Become a New Reality in Belgium
On November 16, 2017 the Belgian Senate adopted an “Act on the Establishment of the Data Protection Authority” (the “Act”). Following Austria, Germany, and the UK, Belgium is the fourth EU Member State to pass a domestic statute implementing the General Data Protection Regulation 2016/679 (“GDPR”) prior to its effective date of 25 May 2018. […]