When Royal Cornwall Hospital responded to a routine Freedom of Information request in 2023, they had no idea they were about to expose sensitive staff data to the public. The hospital recently apologized after discovering that a spreadsheet published on their website contained hidden sickness absence data for 8,100 current and former employees spanning three
Joseph J. Lazzarotti
Joseph J. Lazzarotti is a principal in the Tampa, Florida, office of Jackson Lewis P.C. He founded and currently co-leads the firm's Privacy, Data and Cybersecurity practice group, edits the firm’s Privacy Blog, and is a Certified Information Privacy Professional (CIPP) with the International Association of Privacy Professionals. Trained as an employee benefits lawyer, focused on compliance, Joe also is a member of the firm’s Employee Benefits practice group.
In short, his practice focuses on the matrix of laws governing the privacy, security, and management of data, as well as the impact and regulation of social media. He also counsels companies on compliance, fiduciary, taxation, and administrative matters with respect to employee benefit plans.
Understanding California’s New CCPA Cybersecurity Audit Requirements
After years of development and extensive stakeholder engagement, California has finalized groundbreaking cybersecurity audit regulations under the California Consumer Privacy Act (CCPA). These new requirements may significantly impact how covered businesses protect consumer data.
The New Regulations
The California Privacy Protection Agency (CPPA) Board approved comprehensive amendments to CCPA regulations covering cybersecurity audits, risk assessments…
The CCPA and Automated Decision-Making Technologies (ADMT)
As artificial intelligence (AI), particularly generative AI, becomes increasingly woven into our professional and personal lives—from personalized travel itineraries to reviewing resumes to summarizing investigation notes and reports—questions about who or what controls our data and how it’s used are ever present. AI systems survive and thrive on information and that intersection of AI and…
When Big Doesn’t Mean Bulletproof: The Importance of Third-Party Service Provider Due Diligence
Leaders charged with safeguarding data privacy and cybersecurity often assume that size equates to security—that large, well-resourced organizations must have airtight defenses against cyberattacks and data breaches. It’s a natural assumption: mature enterprises tend to have robust policies, advanced technology, and deep security teams. Yet, as recent events remind us, even the biggest organizations can…
Is a CCPA “Risk Assessment” Required When Using Dashcams?
Key Takeaways
- Outlines basic steps to determine whether a business may need to perform a risk assessment under the California Consumer Privacy Act (CCPA) in connection with its use of dashcams
- Provide a resource for exploring the basic requirements for conducting and reporting risk assessments
If you have not reviewed the recently approved, updated CCPA…
Understanding the CCPA’s New Risk Assessment Requirements – Part 2
As we discussed in Part 1 of this post, the California Privacy Protection Agency (CPPA) has approved significant updates to California Consumer Privacy Act (CCPA) regulations, which were formally approved by the California Office of Administrative Law on September 23, 2025. We began to outline the requirements for a significant new obligation under the…
Understanding the CCPA’s New Risk Assessment Requirements – Part 1
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…
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…
California Sets 30 Day Deadline for Data Breach Notifications
Governor Gavin Newsom recently signed SB 446 into law, introducing significant changes to California’s data breach notification requirements. The bill establishes deadlines for notifying consumers and the state’s Attorney General when personal information of California residents has been involved in a data breach.
What’s Changed Under SB 446
Previously, California law required businesses to notify…
Using Patient Photos in Marketing? OCR Settlement Highlights HIPAA Compliance Requirements
Businesses across many industries naturally want to showcase their satisfied customers. Whether it’s a university featuring successful graduates, a retailer highlighting happy shoppers, or a healthcare facility showcasing thriving patients, these real-world testimonials can be powerful marketing tools. However, when it comes to healthcare providers subject to HIPAA, using patient images and information for promotional…