Julia Jacobson

On Friday, September 23, the California Privacy Protection Agency (CCPA) held a Board meeting about various CPPA administrative activities.
Continue Reading Update on the California Privacy Protection Agency: Still No Date Certain for the CPRA Regulations

We head into the fourth quarter on the heels of the first public California Consumer Privacy Act (CCPA) civil penalty, while also looking ahead to the new state privacy laws in Virginia, Colorado, Connecticut, and Utah and the significant updates that the California Privacy Rights Act (CPRA) will bring to the CCPA. Considering that regulations

On August 24, 2022, California Attorney General Rob Bonta issued a press release announcing the first public settlement by the Office of the Attorney General (OAG) involving alleged violations of the CCPA. The settlement involves a judicial judgment, civil penalties and ongoing monitoring and reporting. The use of noncompliance letters to cajole companies into compliance over many months now appears to be a closed chapter in the CCPA saga. Season 2 promises more drama, more action and more money. Entertaining unless you are the next target!

Continue Reading The Cookie Crumbles – Lessons from First California Consumer Privacy Act (CCPA) Monetary Settlement

The New York Department of Financial Services (“NYDFS”) recently posted a request for public comment on a set of proposed amendments to NYDFS’ current “Cybersecurity Requirements for Financial Services Companies” (“Regulations”).[1] The amendments to the Regulations (“Pre-Proposal Amendments”) are in the “pre-proposal” phase, meaning that the NYDFS will issue official proposed amendments in the near future. Once official proposed amendments are issued, a 60-day public comment period starts, which means that amended Regulations likely will take effect sometime in 2023. In the meantime, entities subject to the Regulations should review the Pre-Proposal Amendments to help ensure sufficient time and resources to implement new requirements.

As background, the Regulations became effective on March 1, 2017, but followed a phased implementation process. The Regulations apply to all entities licensed by the NYDFS (“covered entities”), including banks, insurance companies, money transmitters and other financial services firms doing business in New York. The last phase of the Regulations was implemented in March 2019, at which point the Regulations were fully effective.

Continue Reading The NYDFS Proposes Substantial Amendments to Cyber Regulations

With the continued debate surrounding the laws that dictate how companies across the globe process and protect personal data, CPW’s Julia Jacobson teams up a panel of security experts to examine the concepts of “reasonable” or “appropriate” security and how “reasonable” security translates into a CISO’s day-to-day responsibilities. Join the panelists  as they provide insights