CPRA

The Federal Trade Commission (FTC) has released a staff reportBringing Dark Patterns to Light, which discusses misleading and manipulative design practices—dark patterns—in web and mobile apps. These design choices take advantage of users’ cognitive biases to influence their behavior and prevent them from making fully informed decisions about their data and purchases. Dark patterns are employed to get users to surrender their personal information, unwittingly sign up for services, and purchase products they do not intend to purchase. The consequences of dark patterns have been increasingly noticed in the regulatory and legislative sphere, both in the United States and Europe

Continue Reading Dark Patterns under the Regulatory Spotlight Again

The California Consumer Privacy Act (CCPA) currently has limited carve-outs for personal information (PI) collected from a job applicant, employee, owner, director, officer, medical staff member, or independent contractor of a business acting in such capacity (including, without limitation, communications, emergency contact and benefits PI) (HR data). An even broader exception applies to B-to-B communications and related PI (e.g., vendor, supplier and business customer contacts and communications) (B-to-B data). As a result, businesses subject to the CCPA are not currently required to honor CCPA rights requests received from persons concerning HR data and B-to-B data. These carve-outs are set to sunset on January 1, 2023, when the California Privacy Rights Act (CPRA), which substantially amends the CCPA, goes into full effect, at which point HR data and B-to-B data will be fully subject to all of the requirements of the CCPA/CPRA. Many business administrators had hoped that either the California legislature would extend the HR data exceptions (or maybe even make them permanent), or a federal law that limited data subject rights to traditional consumers would pass and preempt CCPA/CPRA. It is now clear that the former is impossible and the latter is highly unlikely. Accordingly, many companies have a lot to do by year-end to prepare to stand up a CCPA/CPRA program for HR data and B-to-B data.

Continue Reading HR and B-to-B Data Compliance Deadline Looming – Legislative Efforts to Extend California Consumer Privacy Act Exemptions Fail

Welcome to the 2022 Q2 edition of the SPB Artificial Intelligence & Biometric Privacy Quarterly Review Newsletter, your go-to source for keeping you in the know on all recent major artificial intelligence (“AI”) and biometric privacy developments that have taken place over the course of the last three months. We invite you to share this resource with your colleagues and visit Squire Patton Boggs’ Data Privacy, Cybersecurity & Digital Assets and Privacy & Data Breach Litigation homepages for more information about our capabilities and team. 


Q2 did not disappoint in the AI and biometric privacy space, with a number of noteworthy litigation, legislative, and regulatory developments having taken place in these two rapidly developing areas of law. Read on to see what has transpired over the last quarter and what you should keep your eyes on as we head into the second half of 2022.

Continue Reading SPB 2022 Q2 Artificial Intelligence & Biometric Privacy Quarterly Review Newsletter

Earlier this month CPW’s Kristin Bryan and Kyle Fath presented a webinar on “AI and Biometrics Privacy: Trends and Developments” with the International Association of Privacy Professionals (“IAPP”), the largest global community of privacy professionals.  A recording of that webinar is available to all IAPP members and available (for CPE credit) here.

As summarized

In case you missed it, below are recent posts from Consumer Privacy World covering the latest developments on data privacy, security and innovation. Please reach out to the authors if you are interested in additional information.

OOPS! And Other Takeaways from the First Draft of CPRA Regulations

Start Vetting Your Data Processors! Key Takeaways From

In an unexpected move, the California Privacy Protection Agency (the “Agency”) issued draft regulations (“Regs”) mandated by the California Privacy Rights Act (“CPRA”), on Friday May 27 (a day before the Memorial Day weekend, and a day after a public stakeholder meeting in which it gave no indication that the Regs would be issued the

In case you missed it, below are recent posts from Consumer Privacy World covering the latest developments on data privacy, security and innovation. Please reach out to the authors if you are interested in additional information.

The ASA’s Top Tips on Advertising “Free Trials”

FCC Announces Nine More State Robocall Investigation Partnerships

FTC Targets Children’s

CPW is pleased to announce that today David Oberly joins Squire Patton Boggs (US) LLP’s globally-recognized Data Privacy, Cybersecurity & Digital Assets Practice from Blank Rome, where he played an instrumental role in launching the firm’s Biometric Privacy Practice.  As a recognized thought leader in the biometric privacy space, David serves as a go-to expert

As previewed in a recent post, the California Privacy Protection Agency (“CPPA”) held a public meeting on Thursday, February 17. Notably, the CPPA Board (“the Board”) outlined its authority, explained the authority of the CPPA’s Executive Director, and laid out its nearly year-long going forward plan for rulemaking.  The California Privacy Rights Act (“CPRA”),

In case you missed it, below is a summary of recent posts from CPW.  Please feel free to reach out if you are interested in additional information on any of the developments covered.

E-Commerce Platform Data Breach Settlement Receives Final Court Approval – Consumer Privacy World

CPRA Amended and Updates Regarding the CDPA – Consumer