In late August 2023, the California Privacy Protection Agency (“CPPA” or “Agency”) released a discussion draft of proposed regulations under California’s data privacy law, the California Consumer Privacy Act (“CCPA”). Importantly, the proposed regulations set forth more detailed obligations for company cybersecurity programs, including routinely assessing and filing audits with the CPPA. Though these draft […]
Privacy & Cyber Regulatory Enforcement
Oregon Enacts Comprehensive State Privacy Law
On July 18, 2023, Oregon Governor Tina Kotek signed the Oregon Consumer Privacy Act (SB 619)(“OCPA”) into law, making Oregon the eleventh state to enact a comprehensive state privacy law. OCPA will take effect on July 1, 2024, however the effective date for covered non-profits is delayed until July 1, 2025. While OCPA aligns with […]
NIST Cybersecurity Framework 2.0 Released for Public Comment
On August 8, 2023, the National Institute of Standards and Technology (NIST) released the initial draft of its Cybersecurity Framework 2.0 and draft Implementation Examples for public comment. This marks the first significant update to the NIST Cybersecurity Framework (“Framework”) since its initial release in 2014, which is intended to address current and future cybersecurity […]
Oregon Becomes the Fourth State to Enact a Data Broker Law
Oregon Governor Tina Kotek signed into law the Bill Relating to Registration of Business Entities that Qualify as Data Brokers (HB 2052) (the “Act”) on July 27, 2023. Effective January 1, 2024, the Act will require data brokers to annually register with the Oregon Department of Consumer and Business Services (the “Department”). The Act makes […]
FTC Launches Investigation into Creator of ChatGPT
In mid-July, the Federal Trade Commission (FTC) reportedly opened an investigation into OpenAI, the maker of ChatGPT, sending the company an extensive Civil Investigative Demand (CID). While FTC investigations are normally non-public, the Washington Post published what appears to be part of the CID sent from the FTC to OpenAI. This investigation comes on the […]