Sky Blog
On October 27, 2023, the Federal Trade Commission (“FTC”) voted to approve supplemental amendments to the Safeguards Rule (the “Final Rule”) that will require non-bank financial institutions to notify the FTC electronically as soon as possible, and no later than …
There has been significant regulatory attention recently to “dark patterns,” including FTC guidance, state privacy laws, and state and federal enforcement actions. Some of this activity involves new regulations, and some is based on decades-old consumer protection laws …
When we contemplate the numerous challenges regulators and prosecutors face in identifying and redressing corporate and white-collar crime, constitutional criminal procedure is not usually high on the list. If anything, the constitutional doctrines that apply to the government’s interactions with …
Screen scraping – the technique of automatically collecting, parsing, and organizing data from the web – has over the past two decades been used for everything from targeted advertising to price aggregation to academic research. It can, however, be detrimental …
The General Data Protection Regulation (GDPR) has been in effect since May 2018. Although the French data protection authority (CNIL) has imposed the highest fine to date — €50 million on 21 January 2019 — German federal data protection authorities …
As the world greets the New Year, investors and companies may take a moment to reflect on key corporate governance priorities in light of a potentially more challenging business environment in the year ahead. The prospect of slower global economic …
On September 23, 2018, the governor of California signed into law an amended version of the California Consumer Privacy Act of 2018 (CCPA),[1] which was originally enacted in late June 2018. The amendments are a partial response to extensive …
On June 28, 2018, California enacted the California Consumer Privacy Act (the “CCPA” or the “Act”), which will take effect on January 1, 2020.[1] The Act applies to any organization that conducts business in California and satisfies one of …
The massive 2,232-page, $1.3 trillion spending bill signed into law on March 23 by President Trump does more than just fund the government. The bill also contains a provision that will have a significant impact on data privacy. Tacked on …
The winds of change will shortly sweep across the data privacy landscape in the European Union (“E.U.”) and the gale will be felt worldwide. The European General Data Protection Regulation (“GDPR”) will come into force on …
In a move that could cost the EU up to 1.3 percent of its gross domestic product, according to the American Chamber of Commerce to the European Union, on Oct. 6 the European Court of Justice invalidated the 15-year old …
The European Court of Justice (ECJ) followed the core of the Opinion of the Advocate General (AG) (see our Privacy Minute dated October 3, 2015) in Schrems v. Data Protection Commissioner (Case No. C-362/14).
Summary
In sum, the ECJ …