All posts by Cooley

UPDATE: Brazil’s Data Protection Law Moves Forward

The final version of Brazil’s data protection law, Lei Geral de Proteção de Dados (LGPD), was approved by the Brazilian Federal Senate in May 2019 and sanctioned by President Jair Bolsonaro in July. The LGPD is now scheduled to become effective in August 2020. When the LGPD was first approved […]

New York State Toughens Data Security Laws

On July 25, 2019, New York enacted a pair of data security laws. First, the Stop Hack and Improve Electronic Data Security Act (SHIELD Act) updates New York’s data security requirements. Second, the Identity Theft Prevention and Mitigating Services Act imposes obligations on credit reporting agencies that experience a breach […]

Fashion ID Case: CJEU Rules on Plug-ins and Joint Controllership

On 29 July 2019, the Court of Justice of the European Union handed down its decision in the Fashion ID case, dealing with alleged unlawful data collection through the Facebook Like button and the controllership of said data. In short, the CJEU held that websites containing embedded third-party content can […]

UK ICO Cites Inadequate M&A Data Protection Due Diligence as a Factor in Proposing $125M Breach Fine

On July 9, 2019, the UK Information Commissioner’s Office (ICO) publicly announced its intent to impose a £99M (approximately $123M) GDPR fine on Marriott in connection with the discovery and notification of a data breach at Starwood. Among its justifications for the record fine, the ICO cited inadequate data protection […]

Will BA, Marriott Have to Pay UK ICO’s Huge Breach Fines? We Look at What’s Next.

The UK Information Commissioner’s Office (ICO) has issued Notices of Intent (NOI) to fine British Airways (for £183m) and US hotel group Marriott (for £99m) for breaches of the EU General Data Protection Regulation (GDPR). Assuming that fines are ultimately issued, these will be the first fines to be issued […]

Creating Data-Powered Products and Services in the Age of Privacy

On Friday, June 14, Cooley’s cyber/data/privacy practice will be hosting an event focused on the use of data in the development of products and services in our New York office. The intense focus on privacy in the US and globally has raised pressure on businesses that use personal data to create […]

Cooley Launches CCPA Resource Page

To help organizations understand and prepare for the California Consumer Privacy Act (CCPA), Cooley’s cyber/data/privacy team has launched a CCPA resource page, including FAQs, a compliance checklist, recordings of our CCPA webcasts, links to our CCPA blog coverage and more. We welcome your ideas for CCPA topics that you think […]

The End of Auto Insurance As We Know It: How Big Data Will Reshape the Future of the Autonomous Vehicle Insurance Market

Despite the recent wave of articles forecasting that the rise of autonomous vehicles will lead to a decline in auto insurance premiums, we believe it is more accurate to say that the advent of self-driving cars will cause the personal auto insurance policy, as we know it, to disappear at […]

FTC’s Proposed Amendments to the GLBA Safeguards Rule Seek to Incorporate Requirements from NY DFS Cybersecurity Regulations

On March 5, the FTC announced proposed amendments to the Standards for Safeguarding Customer Information under the Gramm-Leach-Bliley Act (“Safeguards Rule” or “Rule”).  The FTC version of the Safeguards Rule applies to financial institutions that are not governed by federal banking regulators (e.g., FDIC, Federal Reserve, OCC, and NCUA) or […]

Cooley’s Michael Rhodes Joins 41 California Privacy Experts Urging Major Changes to the California Consumer Privacy Act

Michael Rhodes, chair of Cooley’s cyber/data/privacy practice, joins 41 California privacy lawyers, professionals and professors urging major changes to the California Consumer Privacy Act (CCPA). Led by Santa Clara University School of Law professor, Eric Goldman, the group is urging the legislature to address six significant issues posed by the […]