On March 15, 2023, the Colorado Attorney General filed final rules implementing the Colorado Privacy Act (“CPA”) with the Secretary of State. The Attorney General first released proposed draft rules on October 10, 2022 and subsequently released revised draft rules on December 21, 2022 and January 27, 2023 after public comment. The final rules will
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Iowa Passes Comprehensive Privacy Statute
On March 15th, the Iowa legislature passed S.F. 262 (the “ICDPA”), making it the sixth U.S. state to pass a comprehensive state privacy statute. The Iowa statute most closely resembles the Utah Consumer Privacy Act (“UCPA”), though it also shares some similarities with the approaches adopted in Virginia, Colorado, and Connecticut. The statute will next
HHS Releases Guidance to Help Healthcare Organizations Align with the NIST Cybersecurity Framework
On March 8, 2023, the United States Department of Health and Human Services (“HHS”), through the Administration for Strategic Preparedness and Response and the Health Sector Coordinating Counsel Joint Cybersecurity Working Group, released an updated version of its Cybersecurity Framework Implementation Guide (the “Guide”) “to help the public and private health care sectors prevent cybersecurity
EDPB Releases its Opinion on the Proposed EU-U.S. Data Privacy Framework
On February 28, 2023, the European Data Protection Board (“EDPB”) released its non-binding opinion on the European Commission’s draft adequacy decision on the EU-U.S. Data Privacy Framework (“DPF”). The adequacy decision, once formally adopted, will establish a new legal basis by which organizations in the EU (as well as the three EEA states of Iceland,
The French CNIL Reminds Two Medical Research Organizations of their Data Protection Obligations
As permitted by the GDPR, France has enacted some specific requirements for the processing of health data, in particular in the context of medical research. Following a report, the French supervisory authority (“CNIL”) audited two organizations carrying out medical research in early 2022 to check their compliance with these requirements. On March 13, 2023, the
TSA Issues New Cybersecurity Requirements for Airport and Aircraft Operators
On March 7, 2023, the United States Transportation Security Administration (“TSA”) announced the issuance of new cybersecurity requirements for airport and aircraft operators on an emergency basis. “The new emergency amendment requires that impacted TSA-regulated entities develop an approved implementation plan that describes measures they are taking to improve their cybersecurity resilience and prevent disruption
Key Takeaways from the Irish DPC’s 2022 Annual Report
On March 7, 2023, the Irish Data Protection Commission (“DPC”) published its annual report for 2022. The report reflects the DPC’s reputation as both an active enforcer of the General Data Protection Regulation (“GDPR”) and a contributor to policy development at national and EU levels. The level of interaction between the DPC and the
China Reveals Plan to Establish a National Data Bureau
On March 7, 2023, during the annual National People’s Congress (“NPC”) sessions, China’s State Council revealed its plan to establish a National Data Bureau (NDB) as part of a broader reorganization of government agencies. The plan is being deliberated by the NPC and is expected to be finalized soon.
White House Releases National Cybersecurity Strategy
The United States National Cybersecurity Strategy, released on March 2, 2023, is poised to place significant responsibility for cybersecurity on technology companies, federal contractors, and critical infrastructure owners and operators. The Strategy articulates a series of objectives and recommended executive and legislative actions that, if implemented, would increase the cybersecurity responsibilities and requirements of
FTC Publishes Blog Post on Data Security Practices for Complex Systems
In February, the Federal Trade Commission (“FTC”) published a blog post that elucidated key security principles from recent FTC data security and privacy orders. Specifically, the FTC highlighted three practices that the Commission regards as “effectively protect[ing] user data.” These practices include: (1) offering multi-factor authentication (“MFA”) for consumers and requiring it for employees; (2)