United Kingdom: Injunctive Relief Against Persons Unknown – The Ransomware Edition

On 11 July 2023, the English High Court handed down its decision on the claimant’s application in Armstrong Watson LLP v. Persons Unknown, granting judgment in default and final injunctive relief. Specifically, the court granted the claimant permanent injunctive relief against persons unknown – a group of unidentified hackers – […]

Breached the GDPR? Calculate your own fine!

The General Data Protection Regulation (GDPR) is a difficult piece of legislation to comply with, and not meeting some of its requirements may lead to hefty fines of up to 4% of global annual revenues of the preceding year or 20 million euros, whichever is highest. Organisations may find it […]

China Issues Measures on Generative Artificial Intelligence Services

On July 13, 2023, the Cyberspace Administration of China (CAC) and six other Chinese government agencies jointly released the final version of the Interim Administrative Measures for Generative Artificial Intelligence Services (see the Chinese version here). These measures will enter into force on August 15, 2023. For background, the CAC […]

SEC Adopts Comprehensive Cybersecurity Disclosure Requirements

On July 26, 2023, the Securities and Exchange Commission (SEC) voted at an open meeting to adopt final rules to mandate standardized cybersecurity disclosures by public companies. The final rules will: The final rules will become effective 30 days after publication in the Federal Register. Companies other than smaller reporting companies […]

White House Releases National Cybersecurity Strategy Implementation Plan

On July 13, 2023, the White House unveiled its National Cybersecurity Strategy Implementation Plan (NCSIP or implementation plan), following the release of the National Cybersecurity Strategy. The implementation plan identifies five pillars that align with the strategy: The administration identified two key motivations for the strategy and implementation plan: The […]

Irish Circuit Court Awards Damages for ‘Non-Material’ Harm Under GDPR

On 11 July 2023, the Circuit Court of Ireland awarded 2,000 euros in compensation to a plaintiff seeking ‘non-material damage’ under Article 82 of the General Data Protection Regulation, in what is believed to be the first case in the European Union to follow the recent Court of Justice of […]

California Attorney General Announces Investigative Sweep Focused on Employment-Related Data

On July 14, 2023, the office of the California attorney general announced an investigative sweep of “large California employers” to request “information on the companies’ compliance with the California Consumer Privacy Act (CCPA) with respect to the personal information of employees and job applicants.” The attorney general has previously conducted […]

Transatlantic Data Economy Simplified: European Commission Adopts Adequacy Decision for EU-US Data Privacy Framework

On 10 July 2023, the European Commission adopted its adequacy decision concluding that the EU-US Data Privacy Framework provides an adequate level of protection for personal data transferred from the European Union (EU) to US companies. Approved by the US following President Joe Biden’s executive order in October 2022, the framework […]

Enforcement of CPRA Regulations Delayed Until 2024

A California court order has delayed enforcement of the implementing regulations for the California Privacy Rights Act of 2020 (CPRA) until March 29, 2024. The California Superior Court of Sacramento County issued the court order on Friday, June 30 — one day before enforcement of the CPRA regulations was originally […]

One Step Closer to a European Law Regulating Artificial Intelligence

On 14 June 2023, the European Parliament adopted its negotiating position on the Artificial Intelligence (AI) Act. The European Parliament’s vote on the AI Act proposal marks a significant milestone toward the regulation of AI within the European Union, as it sets the baseline for inter-institutional negotiations, as further discussed […]