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Banking on an Exemption: Do Universities Qualify as Financial Institutions Exempt from the Illinois Biometric Information Privacy Act?

Is a university a financial institution governed by the Gramm-Leach Bliley-Act (“GLBA”), or are they subject to the Illinois Biometric Information Privacy Act (“BIPA”) and its heightened protections for individuals’ biometric data? This question has animated a series of BIPA cases in Illinois courts over the years, and has spawned…

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Congress Seeks to Protect Children by Allowing Parents and Regulators Access to What Minors Post and View on Social Media

After years of public concern regarding the safety of children on social media platforms, today there is bipartisan congressional support for multiple pieces of legislation that would shift more of the burden and liability of keeping minors safe online to the social media platforms. These laws would mandate that social…

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Thirty-Six Hour Breach Notification Rule Puts Banking Organizations on Notice

In response to the growing threat to financial stability posed by cybersecurity incidents, the Office of the Comptroller of the Currency (OCC), the U.S. Department of the Treasury, the Federal Reserve Board, and the Federal Deposit Insurance Corporation (FDIC) (collectively, the “agencies”) published a rule titled “Computer-Security Incident Notification Requirements…

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