On November 20, 2025, the Securities and Exchange Commission (“SEC”) announced that it was voluntarily dismissing the case it brought against SolarWinds Corp. (“SolarWinds”) and its Chief Information Security Officer, Timothy Brown, regarding the company’s security practices and related statements in connection with the “Sunburst” cybersecurity incident. The SEC stated in a brief release that
Privacy & Data Security
Digital Omnibus Package Series: European Commission’s Proposal to Revise the EU’s AI Rules
On November 19, 2025, the European Commission (“Commission”) officially presented its Digital Omnibus Package (see here and here). In our previous blog post (see here), we explained that this initiative, which represents a comprehensive update to the EU’s digital regulatory landscape, consisted of two proposed regulations: a “Digital Omnibus” that would amend, amongst…
European Commission Proposes Revisions to GDPR and Other Digital Rules Under Digital Omnibus Package
On 19 November 2025, the European Commission (“Commission”) officially presented its Digital Omnibus Package (see here and here). The initiative represents a comprehensive update to the EU’s digital regulatory landscape, which the Commission frames as a competitiveness and simplification initiative aimed at reducing administrative burdens and enhancing legal certainty for businesses. Although the final…
U.S. Senate Introduces the Health Information Privacy Reform Act
On November 4, 2025, Senator Bill Cassidy (R-LA), chair of the Senate Health, Education, Labor, and Pensions (“HELP”) Committee, introduced the Health Information Privacy Reform Act (“HIPRA”). HIPRA seeks to extend protections similar to those provided under the Health Insurance Portability and Accountability Act of 1996, as amended, and its implementing regulations (collectively, “HIPAA”) to…
Cybersecurity Information Sharing Act of 2015 Reauthorized Through January 2026
The Cybersecurity Information Sharing Act of 2015 (“CISA 2015”), which provides protections for sharing cybersecurity threat information with the federal government and others, was reauthorized under the funding bill to reopen the federal government, which was enacted on November 12, 2025. The information sharing mechanisms and protections under CISA 2015, which had previously sunset on…
California Attorney General Announces $530,000 CCPA Settlement with Sling TV
On October 30, 2025, California Attorney General Bonta announced a $530,000 settlement related to allegations that Sling TV, an internet-based live TV service, violated the California Consumer Privacy Act (“CCPA”) and the California Unfair Competition Law. This is the first enforcement action arising from the California Department of Justice’s (“DOJ”) investigative sweep of streaming services…
Global Privacy Regulators Launch Enforcement Sweep Focused on Children’s Data Protection
Last week, the Global Privacy Enforcement Network (“GPEN”)—a global network of over 30 national data protection authorities—announced the launch of its annual privacy sweep. The purpose of the sweep is to examine how websites and mobile applications commonly used by children handle minors’ personal information. Members of GPEN include regulators who have long prioritized…
Roundup of Cross-Border Data Transfer Developments
Over the past few months, there have been several notable developments in the cross-border data frameworks of the U.S., EU, UK, Brazil, and several Asia Pacific (“APAC”) countries. These developments reflect evolving regulatory approaches to international data flows, trade agreements, and national security priorities—each with certain nuances and particularities that multinational companies need to understand…
California Finalizes Updates to Existing CCPA Regulations
On September 23, 2025, the California Privacy Protection Agency announced that the state’s Office of Administrative Law approved regulations that update existing California Consumer Privacy Act (“CCPA”) regulations and introduce new regulations covering cybersecurity audits, risk assessments, and automated decision-making technology. The updates to the existing regulations—which take effect on January 1, 2026—expand business obligations…
EDPB to Focus on Transparency in 2026 Enforcement
On October 14, 2025, the European Data Protection Board (“EDPB”) announced that its 2026 coordinated enforcement action (“CEA”) will focus on transparency and information obligations — the rules that require organizations to clearly explain how they collect, use, and share personal data — under Articles 12-14 of the General Data Protection Regulation (“GDPR”).…