On July 16, 2024, the California Privacy Protection Agency (the “CPPA”) board declined to advance to formal rulemaking California Consumer Privacy Act (“CCPA”) draft regulations on cybersecurity audits, risk assessments, automated decisionmaking technology, insurance companies and updates to existing regulations. The CPPA board voted against advancing the regulations during its board meeting when it also […]
Privacy & Cyber Regulatory Enforcement
California AG Announces $500,000 Settlement with Mobile Game App Company for Unlawful Collection and Sharing of Children’s Data
On June 18, 2024, California Attorney General (“AG”) Rob Bonta and Los Angeles City Attorney Hydee Feldstein Soto announced a settlement with a video game developer and publisher regarding allegations that the company violated the California Consumer Privacy Act (the “CCPA”), the federal Children’s Online Privacy Protection Act (“COPPA”) and California’s Unfair Competition Law (the […]
What to Tell Your C-Suite About the EU AI Act
On July 12, 2024, the European Union’s long-awaited Artificial Intelligence Act (AI Act) was finally published. It will enter into force on the twentieth day following its publication; i.e., on August 1, 2024. The AI Act is a landmark legal framework that imposes obligations on both private and public sector actors that develop, import, distribute, […]
SEC Corporation Finance Provides Additional Guidance on the Disclosure of Material Cybersecurity Incidents in Form 8-K
On June 24, 2024, the Division of Corporation Finance (“Corp Fin”) of the Securities and Exchange Commission (“SEC”) issued five new Compliance and Disclosure Interpretations (“C&DIs”) related to the disclosure of “material” cybersecurity incidents in Item 1.05 of Form 8-Ks. The C&DIs present hypothetical fact patterns related to ransomware attacks and insurance reimbursement for damages […]
SEC Settlement Suggests the Agency’s Attempt to Regulate Cybersecurity Controls
On June 18, 2024, the SEC announced a $2.125 million settlement with R.R. Donnelley & Sons Co. (“RRD”) related to the company’s 2021 ransomware attack (the “Incident”). The settlement, and the SEC’s accompanying cease-and-desist order (the “Order”), portend the agency’s continued and increasing oversight over registrants’ cybersecurity policies and practices. Background RRD is a global […]