Theodore Christakis, Professor of International Law at the University Grenoble Alpes and Senior Fellow and Director of Research for Europe at the Cross-Border Data Forum, has published a new comprehensive analysis on cross-border transfers of personal data and the EU’s data protection authorities’ “Zero Risk” theory developed since the CJEU Schrems II Judgment. Prof. Christakis looks […]
Privacy & Cyber Regulatory Enforcement
Declassified Intelligence Community Letters Highlight Importance of Monitoring Outbound Data Flows
On January 25, 2024, Senator Ron Wyden (D-OR) released documents that confirm U.S. intelligence agencies are purchasing location and other sensitive personal information from data brokers without the consent of the data subjects. The FTC has recently gone after data brokers who collect and sell the sensitive location data of consumers without their express consent, […]
California Court of Appeals Paves the Way for Enforcement of California Privacy Rights Act Regulations
On February 9, 2024, the California state court of appeals mandated a trial court to vacate its order and judgment prohibiting the California Privacy Protection Agency (the “Agency”) from enforcing the California Privacy Rights Act regulations (the “CPRA Regulations”) until March 29, 2024. The Agency will be able to enforce the CPRA Regulations upon the […]
NYDFS Releases Circular Letter on Use of AI in Insurance Underwriting and Pricing
On January 17, 2024, the New York State Department of Financial Services (“NYDFS”) issued a proposed circular letter for comment regarding the “Use of Artificial Intelligence Systems and External Consumer Data and Information Sources in Insurance Underwriting and Pricing” (the “Circular Letter”). The Circular Letter details NYDFS’ expectations and guidelines for the use of artificial […]
Washington AG’s Office Updates FAQs for My Health My Data Act
The Office of the Attorney General of Washington (the “AG”) has updated the Frequently Asked Questions (the “FAQs”) for the Washington My Health My Data Act (the “Act” or “Washington Act”) to provide guidance on the AG’s position concerning whether businesses must publish standalone consumer health data privacy policies under the Act. The update, first […]