On November 3, 2022, the California Privacy Protection Agency (“CPPA”) issued a notice of modifications to the Proposed Regulations implementing the California Privacy Rights Act (“CPRA”). These proposed modifications come in response to public comments on, and are meant to clarify, previously issued modifications. The modifications, which are largely based on the Modified Proposed Regulations […]
Privacy & Cyber Regulatory Enforcement
Recent FTC Order Has Implications for Executive Liability and Corporate Data Minimization Practices
On October 24, 2022, the Federal Trade Commission (“FTC”) announced a proposed consent order against both Drizly LLC, an online marketplace for alcohol delivery, and its CEO over the company’s alleged security failures that led to a data breach in 2020, which exposed the personal information of approximately 2.5 million Drizly customers. Drizly and its […]
NYDFS Announces Significant Cybersecurity Settlement with EyeMed Vision Care
On October 18, 2022, EyeMed Vision Care LLC (“EyeMed”) entered into a Consent Order with the New York Department of Financial Services (“DFS”) relating to a cybersecurity event from 2020 that exposed consumer nonpublic information (“NPI”) to an unauthorized individual. EyeMed agreed to pay DFS a $4.5 million penalty, in addition to implementing mandatory remediation […]
Heavier Breach Notification Obligations for U.S. Companies Subject to the EU GDPR According to Proposed Regulatory Guidance from the EDPB
On October 18, 2022, the European Data Protection Board (“EDPB”) published a proposed updated version of its regulatory guidance on personal data breaches under the EU GDPR (the “Proposed Updated Guidance”). The Proposed Updated Guidance seeks to place heavier personal data breach notification obligations on controllers established in the U.S. (and other non-EU countries) but […]
California Privacy Protection Agency Publishes Updated CPRA Regulations
Today, October 17, 2022, the California Privacy Protection Agency (“CPPA”) published its first set of Modified Proposed Regulations under the California Privacy Rights Act (“CPRA”). The Modified Regulations have been published in preparation for a scheduled meeting of the CPPA Board on October 21 and 22 to discuss possible actions regarding the proposed regulations. Along […]