The GDPR entered into force on May 25, 2018. One of the GDPR’s core going-forward obligations is the duty to conduct Data Protection Impact Assessments (DPIAs) over processing activities that create a “high risk” to individuals’ privacy. DPIAs constitute an important aspect of GDPR compliance, as they arguably replace the notifications of processing systems and […]
Mobile Privacy
In Order, FTC Recognizes Lower Notice Requirements for “Consumer-Expected” Data Collection
Last week, the Federal Trade Commission granted a petition by Sears Holding Management seeking modification of a 2009 Commission Order. The notable 2009 Order settled allegations that Sears had improperly failed to provide notice regarding data collection by certain software the company offered to consumers. Sears argued that the 2009 Order placed it at a […]
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 […]
David Keating, Jan Dhont and Karen Sanzaro to Speak at the 2017 Privacy + Security Forum
David Keating, partner and co-leader of the firm’s Privacy & Data Security practice, Jan Dhont, Brussels partner and head of the firm’s European Privacy and Data Protection practice, and Karen Sanzaro, counsel in the Technology & Privacy Group, will be speakers at the 2017 Privacy + Security Forum in Washington, DC, taking place on October 4-6, […]
FTC Staff Releases Report on Cross-Device Tracking
The Federal Trade Commission (FTC) recently released its staff report on Cross-Device Tracking. Cross-device tracking refers to the tracking of consumer activity across multiple devices such as smartphones, desktops, tablets and other connected devices. It helps companies understand consumer behavior better. The tracking can be deterministic (where a user logs into multiple devices affirmatively identifying […]