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A senior member of our Data Privacy & Cybersecurity Practice Group, Glenn Brown provides business-oriented advice to clients in numerous industries on data privacy and regulatory compliance matters, including regulatory investigations and examinations. He has experience driving privacy and compliance priorities within organizations and providing strategic counsel regarding privacy, compliance and risk to support the growth and success of the business.

Glenn also has deep experience advising clients regarding compliance with many of the US federal and state privacy laws, including the California Consumer Privacy Act (CCPA), the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act and the Driver’s Privacy Protection Act. Glenn is familiar with the legislative and regulatory landscape in the US and the EU and assists clients with developing strategies to address new developments.

Having served in-house in the capacity of Associate General Counsel and Chief Compliance Officer for more than 10 years, Glenn has a first-hand understanding of the day-to-day issues faced by clients when creating corporate privacy programs, implementing corporate compliance systems and responding to government investigations and examinations.

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The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) maintains the Specially Designated Nationals (“SDN”) list, which is published to identify suspected terrorists and other bad actors.  US persons are generally prohibited from dealing with anyone on the list, so companies and governments regularly run checks against the SDN list and other

Cyber insurance is top of mind lately due to heightened cyber vulnerabilities caused by an expanding remote workforce.  Thankfully, Consumer Privacy World privacy pros provided some great guidance in their article “CGL Exclusions For Cyberattacks and Loss of Electronic Data:  Is There A Gap In Your Coverage” published in the American Bar Association’s

In a recent case from the Eastern District of Pennsylvania[1], the court provided some helpful clarifications regarding the reinvestigation obligations of a consumer reporting agency (“CRA”) under the Fair Credit Reporting Act (“FCRA”).  Section 611(a) of the FCRA requires a CRA to conduct a reasonable reinvestigation of any item of information in a

A recent decision in the Eastern District of Pennsylvania confirms Third Circuit precedent that an employer’s failure to provide a consumer with notice of their rights under the Fair Credit Reporting Act (“FCRA”), as required by the FCRA, does not cause an injury-in-fact where the plaintiffs ultimately became aware of their rights and timely brought

As of today, July 1, 2020, the California Attorney General (“AG”) will begin enforcing the California Consumer Privacy Act of 2018 (“CCPA”), which went into effect on January 1, 2020.  Under the CCPA, the AG may recover civil penalties of up to $2,500 for each violation and up to $7,500 for each intentional violation.  The

A recent case in the Northern District of Minnesota[1] helpfully confirmed that although consumer reporting agencies (“CRAs”) are required by the Fair Credit Reporting Act (“FCRA”) to ensure that the consumer reports are accurate, they are not obligated to include information on all (or any) credit accounts (or “tradelines”) relating to a consumer.

Plaintiff

This case from the Southern District of West Virginia was brought by a husband and wife, alleging that furnisher Ally Financial (“Ally”) violated the FCRA by failing to conduct a reasonable reinvestigation following their dispute regarding the accuracy of information furnished by Ally.[1]  In denying Ally’s Motion to Dismiss, the court found that what constitutes

In an odd turn of events, a plaintiff brings a putative class action for alleged violations of the Fair Credit Reporting Act (“FCRA”) but later claims that she has not asserted claims sufficient to allege an “injury in fact.” Defendant contends that Plaintiff has actually asserted claims to demonstrate that she has suffered concrete injuries.