October was a particularly busy month, with headline-grabbing stories such as the long-awaited finalisation of the fines against British Airways and Marriott, which may well be the last penalties the UK Information Commissioner’s Office (the “ICO”) issues as a GDPR Lead Supervisory Authority.  Having already covered both fines (here and here), and the French CNIL’s latest cookies guidance, below is…

California voters have approved the new California Privacy Rights Act (“CPRA”). The margin was 56% – 44% – comfortable, if significantly tighter than pre-election polling that showed CPRA winning in a landslide. That comes on the heels of the California Attorney General’s release of still more proposed amendments to the regulations for the existing California Consumer Privacy Act (“CCPA”). Below…

Hot on the heels of British Airways’ £20m fine (covered here), the UK Information Commissioner’s Office has fined Marriott £18.4m for alleged data security failings linked to the breach of 339 million guest records.  Like the British Airways fine, the penalty is a significant climb-down from the amount originally proposed (£99m) in July 2019.  The penalty notice provides helpful insights…

Earlier this month, the Personal Data Protection (Amendment) Bill was read for the first time in Singapore’s Parliament. As we reported previously, in May 2020, Singapore’s Ministry of Communications and Information (“MCI”) and Personal Data Protection Commission (“PDPC”) launched an online public consultation on a draft bill which proposed long-awaited amendments to Singapore’s Personal Data Protection Act 2012 (the “PDPA”),…

In a long-awaited final decision, the UK Information Commissioner’s Office (the “ICO”) has issued a fine of £20m to British Airways (“BA”) following a data breach that took place in 2018.  Although by some way the largest fine ever issued by the ICO, this represents a significant reduction from the £183.39m fine initially proposed by the ICO in July 2019,…

On October 13, 2020, Anna Gressel and Avi Gesser from Debevoise’s Data Strategy and Security Group, along with their special guest, Jon Godfread, North Dakota Commissioner of Insurance and Chair of the National Association of Insurance Commissioners (NAIC) Artificial Intelligence Working Group, had an insightful conversation concerning the NAIC AI Working Group’s Principles on Artificial Intelligence, including: Implementing systematic risk management…

On October 1, 2020, the French data protection authority, the CNIL (“Commission Nationale de l’Informatique et des Libertés”) issued guidelines on the use of cookies and trackers (the “Guidelines”). These Guidelines are meant to clarify applicable law and to help public and private entities establish good practices for their use of cookies and similar technologies in France. The CNIL also…

Earlier this year, we shared a list of 13 technical and nontechnical measures companies can adopt to mitigate the risks of ransomware attacks. With ransomware and other malicious cyber-related attacks continuing to grow in frequency, scope and sophistication, two divisions within the U.S. Treasury Department issued advisories last week detailing risks and considerations regarding financial transactions related to these events. …

Throughout September, companies, regulators and policymakers have continued to respond to the fallout from Schrems II.  Since our last update we have also seen the second largest fine to date under the GDPR, the start of a major class action against YouTube, as well as a raft of new policy developments covering topics ranging from artificial intelligence to antitrust in…

The business-to-business (“B2B”) and human resources (“HR”) exemptions to the California Consumer Privacy Act (“CCPA”) have been extended for a full year, and will now expire no sooner than January 1, 2022 – and a further one-year extension seems likely. The B2B and HR exemptions have thus far permitted businesses to omit these types of data from their CCPA compliance…