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 […]
Legislation
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 […]
The California Privacy Rights Act of 2020 – Key Impacts
On Monday, Alastair Mactaggart and his group, Californians for Consumer Privacy, announced its collection of over 900,000 signatures in support of its ballot initiative, a number well in excess of the approximately 620,000 required for placement on the November ballot. The initiative, called the “California Privacy Rights Act of 2020,” would amend the 2018 California […]
California Attorney General Issues Second Round of Modifications to CCPA Regulations
At approximately 6:00 p.m. today, March 11, 2020, California Attorney General Xavier Becerra announced a second round of modifications to the draft regulations his office is preparing for the California Consumer Privacy Act (the “Draft CCPA Regulations”). These modifications follow two previous rounds of drafting: (a) the initial publication of the Draft CCPA Regulations, in […]
SHIELD Act Overhauls New York’s Data Breach Notification Framework
On October 23, 2019, New York’s new breach notification provisions came into effect, a result of New York’s passage of the Stop Hacks and Improve Electronic Data Security Act (SHIELD Act) in July. That Act overhauled New York’s data privacy framework, expanding the list of data elements that are considered “private information” while growing the […]