The California Privacy Protection Agency (CPPA) issued its first enforcement advisory concerning the California Consumer Privacy Act (CCPA). In Enforcement Advisory No. 2024-01, the CPPA tackles a foundational principle – data minimization. Much of the attention surrounding the CCPA seems to focus on website privacy policies, notices at collection, and consumer rights requests. With

As Cybersecurity Awareness Month wraps up, it’s worth mentioning that employee security awareness training is an ongoing process. Employee error remains a significant contributing factor in data breaches. According to  the 2022 Verizon Data Breach Report, “74% of all breaches include the human element… error, privilege misuse, use of stolen credentials or social engineering.”

There are numerous cybersecurity regulations and requirements for businesses to worry about but they may not be considering their cybersecurity regulations under privacy statutes. California was at the forefront of privacy regulations with the passage of the California Consumer Privacy Act (CCPA). Lawsuits under the CCPA began almost immediately after it was enacted in 2020.

This year, Indiana joined several other states to pass a comprehensive consumer privacy law, that becomes operative on January 1, 2026. Like other consumer privacy laws, Indiana’s law requires businesses to establish reasonable administrative, technical, and physical security practices to protect the confidentiality, integrity, and accessibility of personal data, which implicates cybersecurity concerns.

Effective July 10, 2023, the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”) replaced the invalidated EU-U.S. Privacy Shield framework (“Privacy Shield”). Participating U.S. organizations can now receive personal data transferred from the European Economic Area in compliance with the EU General Data Protection Regulation and without being subject to further conditions.  

Similar to the Privacy

Though enforcement of the California Privacy Rights Act (CPRA) which amended the California Consumer Privacy Act (CCPA) has been paused for now, the State of California is not resting when it comes to compliance with the CCPA.

On July 14, 2023, California’s Attorney General announced an “investigative sweep” regarding compliance with the CCPA.

FTC Safeguards Law (and Car Dealerships)

June 9th marked the deadline for financial institutions, including certain non-banking institutions that collect or maintain sensitive customer information (e.g., car dealerships), to implement a comprehensive information security program to comply with the Federal Trade Commission’s updated Safeguards Rule. For additional information, see our post: Reminder: The