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
Mary T. Costigan
Mary T. Costigan is a principal in the Berkeley Heights, New Jersey, office of Jackson Lewis P.C. and a core member of the firm’s Privacy, Data and Cybersecurity practice group. She holds a Certified Information Privacy Professional/US designation from the International Association of Privacy Professionals (iapp).
Mary advises regional, national and multinational clients across various industries on data privacy and cybersecurity laws and best practices including employee monitoring, internet privacy, biometric data collection, artificial intelligence, the California Consumer Privacy Act (CCPA), HIPAA, and the EU General Data Protection Regulation.
Mary has extensive experience helping clients respond to cybersecurity incidents including ransomware attacks.
New Jersey Legislature Enacts the First Consumer Privacy Law of 2024
On January 16, 2024, New Jersey’s Governor signed Senate Bill (SB) 332, which establishes a consumer data privacy law for the state. New Jersey becomes the 13th state to pass a comprehensive data consumer privacy law. The law would take effect one year after its enactment, on January 15, 2025.
To whom…
Data Protection Update: Q4 Noteworthy Dates
Cross Border Transfers of Data.
UK Data Transfers. The UK government has published a U.S. “adequacy decision” which permits U.S. organizations that have certified to the EU-US Data Privacy Framework (DPF) and UK Extension to receive personal data transferred from the UK to the U.S. after October 12, 2023.
China Data Transfers. November…
Cybersecurity Awareness Month Series: Employee Cybersecurity Awareness Training
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.”…
Cybersecurity Awareness Month Series: The California Consumer Privacy Act and Cybersecurity
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.
Cybersecurity Awareness Month Series: Cybersecurity in the Hoosier State
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.
Transatlantic Transfers of Personal Data: Transferring a Privacy Shield Certification to the New EU-U.S. Data Privacy Framework
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…
CCPA-Covered Businesses Be On the Look Out for a Letter from the California Attorney General
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.
Data Protection Update: Q3 Noteworthy Dates
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 …
Data Protection Update: Q2 2023
- The New York City Local Law 144, Automated Employment Decision Tools: April 15, 2023.
- California Consumer Privacy Act Regulations: July 1, 2023.
- Colorado Consumer Privacy Act (