Last Friday, the California Senate and Assembly passed SB-1121, amending the California Consumer Privacy Act (“CCPA”) as enacted in June. We previously issued an advisory following the June enactment, and will host a webinar discussing the law (as now amended) on September 12. This blog post highlights some of the key amendments to the CCPA. […]
Privacy & Cyber Regulatory Enforcement
NYDFS Cybersecurity Requirements Compliance Deadline Nears for Key Provisions
September 4, 2018 marks the end of the transitional period for covered entities to comply with several key provisions of the NYDFS Cybersecurity Requirements that require certain systemic and sustained measures. These provisions include the encryption and audit trail requirements as well as ones relating to the implementation of monitoring policies, procedures, and controls, application […]
CFPB Changes Annual Notice Requirement Under Reg. P
On Friday, the Consumer Financial Protection Bureau announced its “finalized amendments” to Regulation P, an implementing regulation of the federal financial Gramm Leach Bliley Act. Regulation P governs the provision of privacy notices for covered financial institutions. In response to legislation passed by Congress in late 2015, the final rule issued Friday permits financial institutions […]
Alston & Bird Hosts Sept. 12 Webinar on California Consumer Privacy Act
Save the date! On Sept. 12, 1 – 2 PM ET, Alston & Bird will host a webinar to analyze the new California Consumer Privacy Act. (You can read our prior advisory.) The California Consumer Privacy Act has been compared to the European Union’s General Data Protection Regulation due to its creation of important new privacy […]
LabMD: The End of the FTC in Cyber or Just a New Path?
The U.S. Court of Appeals for the Eleventh Circuit recently issued its opinion in LabMD, Inc. v. FTC, No. 16-16270 (11th Cir. June 6, 2018), declaring unenforceable a Federal Trade Commission (FTC) order requiring LabMD to implement an extensive cybersecurity plan. The case is noteworthy for its lengthy procedural background—during which time LabMD became defunct—and its holding, which […]