On March 6, 2026, the Administration released “President Trump’s Cyber Strategy for America” alongside an Executive Order (entitled “Combating Cybercrime, Fraud, and Predatory Schemes Against American Citizens”) and accompanying Fact Sheet.  The framework set forth in the Strategy document is significantly shorter and higher-level than the prior National Cybersecurity Strategy issued in…

In February 2026, the Spanish data protection authority (Agencia Española de Protección de Datos, “AEPD”) published guidance on data protection issues related to the use of AI agents. The guidance follows an earlier, similar analysis by the UK Information Commissioner’s Office, which we discussed in a prior blog post.

Helpfully, AEPD’s guidance maps key…

On February 13, 2026, France’s highest administrative court (“Conseil d’État”) delivered an important decision clarifying the boundary between pseudonymization and anonymization under the GDPR. The ruling confirms that data which remain re‑identifiable in practice—even with some effort—must be treated as personal data under the GDPR by service providers, unless the risk of re‑identification by such…

On February 10, 2026, federal district court Judge Jed S. Rakoff ruled from the bench in the Southern District of New York that the attorney-client privilege and the work product doctrine did not protect legal strategy materials that a criminal defendant generated using a generative AI tool, when he used a public version of the…

On January 28, 2026, the U.S. Cybersecurity and Infrastructure Security Agency (CISA) published a new resource on Assembling a Multi-Disciplinary Insider Threat Management Team.  The guidance is intended to assist critical infrastructure stakeholders, which includes private sector entities across various sectors, with implementing an insider threat mitigation program that combines physical security, cybersecurity, personnel…

On February 19, 2026, the UK Court of Appeal handed down its decision in DSG Retail Limited v The Information Commissioner [2026] EWCA Civ 140. The Court ruled that a controller’s data security duty applies to all personal data for which it acts as controller – irrespective of whether the information would constitute personal…

Earlier this month, the U.S. Cybersecurity and Infrastructure Security Agency (“CISA”) announced a series of public town hall meetings to solicit additional stakeholder input on the Notice of Proposed Rulemaking (“Proposed Rule”) implementing the Cyber Incident Reporting for Critical Infrastructure Act of 2022 (“CIRCIA”), which CISA published in April 2024.  

Background

CIRCIA established two…