All posts by Cooley

Cybersecurity Governance for Maturing Companies

With cyber resilience top of mind for investors, shareholders, regulators and the plaintiffs’ bar, growing organizations can no longer afford to put their cybersecurity efforts on the back burner. Building a cybersecurity program has become an essential element in the growth strategy. But where do you begin? Cooley’s cyber/data/privacy lawyers […]

Brexit and its Possible Impact on Data Transfers

In its strictest construction, what ‘Brexit’ means is clear, what it entails and what comes next is absolutely not. Therefore, this article will not focus on matters relating to any such future relationship, but rather only on the terms on which the UK may leave the EU and how that […]

California Consumer Privacy Act of 2018 – Full Text

For your ease of reference, we reproduce here a formatted, hyperlinked copy of the California Consumer Privacy Act of 2018 (CCPA), current as of October 15, 2018. We’ve included in parentheses the general topic for each section, though this is our own interpretation and not set out in the CCPA […]

GDPR DPO University – October 18

On Thursday, October 18, Cooley’s cyber/data/ privacy practice will be holding GDPR DPO University in our New York office. The EU General Data Protection Regulation has required many organizations to appoint Data Protection Officers. With demand for DPOs far outstripping the supply, many newly-minted DPOs need to quickly develop data […]

GDPR and AML – a perfect pair?

The General Data Protection Regulation (GDPR) has been one of the most highly anticipated and talked about changes to the legal sphere in years, affecting the vast majority of businesses and individuals alike. The primary focus to date has been on the implementation deadline of 25 May 2018 and the […]

FAQs on the California Consumer Privacy Act of 2018 – Part 1: The Basics

On June 28, 2018, the California Legislature passed Assembly Bill 375 and enacted the California Consumer Privacy Act of 2018 (the “CaCPA” or the “Act”). The Legislature rushed the bill through in order to preempt a more stringent privacy initiative from appearing on the November ballot, which if passed would have been […]

Crypto Up Next for IRS Enforcement

In an effort to maximize its limited resources, the IRS’ Large Business and International Division has been identifying issues that present greater risks of noncompliance. The list of identified issues has been growing since January 2017. Recently, the IRS added cryptocurrency to its list of compliance campaigns. In 2014, the […]

California Passes Sweeping Consumer Privacy Act

On June 27 the California Senate and Assembly unanimously approved the California Consumer Privacy Act of 2018 (CCPA), and Governor Jerry Brown signed it into law the same day. The CCPA was rushed through the legislative process to avoid passage of a more stringent privacy law planned for California’s November […]

GDPR – Do I Need Consent to Process Personal Data?

If you are handling personal data of EU citizens, you will need some justification in order to do so. Under the new rules, the basic concept of consent has not changed, nor has its role as a lawful basis for processing personal data: consent remains a possible option. However, the […]

US Supreme Court: Fourth Amendment Applies to Cellphone Tracking

In a landmark Fourth Amendment decision in Carpenter v. United States, delivered on June 22, the Supreme Court addressed the intersection of privacy and law enforcement in the digital age. It held that law enforcement officials must obtain a search warrant based on probable cause in order to compel cellular service providers […]