The California Privacy Protection Agency (CPPA) has adopted significant updates to the California Consumer Privacy Act (CCPA) regulations, which were formally approved by the California Office of Administrative Law on September 23, 2025. These comprehensive regulations address automated decision-making technology, cybersecurity audits, and risk assessments, with compliance deadlines beginning in 2026. Among these updates, the
Governance, Risk, and Compliance
AI Adoption Surges Among S&P 500 Companies—But So Do the Risks
According to Cybersecurity Dive, artificial intelligence is no longer experimental technology as more than 70% of S&P 500 companies now identify AI as a material risk in their public disclosures, according to a recent report from The Conference Board. In 2023, that percentage was 12%.
The article reports that major companies are no longer…
Florida AHCA Proposed Rules Would Establish New Breach Reporting, Continuity Planning Requirements
On September 17, 2025, the Florida Agency for Health Care Administration (AHCA) will hold its first public meeting to discuss proposed rules designed to enhance transparency and preparedness around health care information system breaches. AHCA is Florida’s agency responsible for the state’s Medicaid program, the licensure of the state’s health care facilities, and the sharing…
AI Notetaking Tools Under Fire: Lessons from the Otter.ai Class Action Complaint
The rapid adoption of AI notetaking and transcription tools has transformed how organizations (and individuals) capture, analyze, and share meeting and other content. But as these technologies expand, so too do the legal and compliance risks. A recent putative class action lawsuit filed in federal court in California against Otter.ai, a leading provider of AI…
CCPA Enforcement Action Highlights CPPA Focus on Opt-Out Rights, Website Functionality, and Reliance on Service Providers
On May 1, 2025, the California Privacy Protection Agency (CPPA) issued a Final Order in one of its first public enforcement actions under the California Consumer Privacy Act (CCPA), imposing a fine of nearly $350,000 on the business.
An important take away from the Final Order: simply posting a privacy policy is not enough. Businesses…
When Minor Variations in Prompts Lead to Problematic Outputs
The Senate recently voting 99-1 to remove a 10-year moratorium on state regulation of AI says something about the impact of AI, but also its challenges.
A new MIT study, presented at the ACM Conference on Fairness, Accountability and Transparency, demonstrates that large language models (LLMs) used in healthcare can be surprisingly “brittle.” As…
Happy Privacy Day: Emerging Issues in Privacy, Cybersecurity, and AI in the Workplace
As the integration of technology in the workplace accelerates, so do the challenges related to privacy, cybersecurity, and the ethical use of artificial intelligence (AI). Human resource professionals and in-house counsel must navigate a rapidly evolving landscape of legal and regulatory requirements. This National Privacy Day, it’s crucial to spotlight emerging issues in workplace technology…
New Jersey Attorney General: NJ’s Law Against Discrimination (LAD) Applies to Automated Decision-Making Tools
This month, the New Jersey Attorney General’s office (NJAG) added to nationwide efforts to regulate, or at least clarify the application of existing law, in this case the NJ Law Against Discrimination, N.J.S.A. § 10:5-1 et seq. (LAD), to artificial intelligence technologies. In short, the NJAG’s guidance states:
the LAD applies to algorithmic discrimination…
AI versus MFA
Ask any chief information security officer (CISO), cyber underwriter or risk manager, or cybersecurity attorney about what controls are critical for protecting an organization’s information systems, you’ll likely find multifactor authentication (MFA) at or near the top of every list. Government agencies responsible for helping to protect the U.S. and its information systems and assets…
Investigation of AI Training by Australian Radiology Provider Provides Important Reminder for U.S. Healthcare Providers
If there is one thing artificial intelligence (AI) systems need is data and lots of it as training AI is essential for achieving success for a given use case. A recent investigation by Australia’s privacy regulator into the country’s largest medical imaging provider, I-MED Radiology Network, illustrates concerns about the use of medical data to…