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Multistate Privacy Enforcement Sweep Puts Global Privacy Control in the Spotlight

Recent enforcement actions and announcements from the California Privacy Protection Agency (CPPA) and state Attorneys-General (AGs) in California, Colorado and Connecticut, and a California bill that passed the state legislature, signal a new phase of heightened enforcement, focused on honoring consumers’ opt out requests, including through cookie banners and the…

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California’s New Privacy and Cybersecurity Regulations on Risk Assessments, Automated Decision making and Cybersecurity Audits: What Businesses Need to Know

During a Board Meeting on July 24, 2025, the California Privacy Protection Agency (CPPA) unanimously approved the long-awaited final text of its second rulemaking package, implementing a broad swath of new requirements regarding risk assessments, automated decisionmaking technology (ADMT), and cybersecurity audits. The regulations, under the California Consumer Privacy Act (CCPA), also…

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California Forges a New Path on Automated Decision-Making Technology, Risk Assessments, and Cybersecurity Audits

Introduction As the United States transitions to a new administration, federal policymaking is beginning to shift away from civil rights and other Biden-era AI governance priorities and towards AI policies focused on “out-innovating the rest of the world,” securing US technological advantage, and national security, defense, and cybersecurity. In the…

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Texas’ New Privacy Law Goes Into Effect – and Attorney General Builds Enforcement Team

Since the passing of the California Consumer Privacy Act (CCPA) in 2018, California has led the nation in privacy regulation and enforcement. But, beginning July 1, 2024, Texas will be the new sheriff in town. On July 1, Texas’ Data Privacy and Security Act goes into effect as one of the strongest…

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Goodwin’s 2024 Data, Privacy & Cybersecurity Outlook

As we kick off 2024, many of us are wondering what this year’s hot topics and trends will be in the privacy and cybersecurity sector. Will AI continue to be the trendsetter, even among privacy regulators? And what will businesses do to keep up to date with all emerging laws,…

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EU Court of Justice Confirms GDPR Security Measures Can Be “Appropriate” Even If Not Foolproof

On December 14, 2023, the EU Court of Justice (“CJEU”) issued its first ever ruling on the scope of data security requirements under the GDPR. In VB v. NAP, the CJEU held that an organization is not liable for a security breach unless it failed to implement appropriate security measures….

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What Does the Irish DPC’s 1.2 Billion Euro Data Transfer Fine Mean For EU-US Transfers?

On 22 May 2023, the Irish Data Protection Commission (“DPC”) fined Facebook parent Meta EUR 1.2 billion for transferring personal data to the U.S. in violation of GDPR. The DPC also ordered Meta to suspend further transfers unless it can bring such transfers into compliance within 5 months. Meta is…

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European Top Court Confirms Companies Need to Name “Recipients” of Personal Data When Responding to Access Requests, Not Just Categories

On January 12, 2023, the Court of Justice of the European Union (“CJEU”) ruled in case C-154/21 | Österreichische Post AG that controllers must provide the specific identity of any “recipient” of personal data in response to a GDPR access request. While the GDPR itself states that controllers may inform…

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EU Commission Publishes Draft Adequacy Decision on Privacy Shield 2.0

On December 13, 2022, the European Commission published a draft adequacy decision on the EU-US Data Privacy Framework (the “Framework”), the successor to the EU-US Privacy Shield Framework that was famously struck down by Europe’s top court two years ago. While the purpose of the draft adequacy decision, once adopted,…

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