Robert E. Braun and Michael A. Gold, co-chairs of JMBM’s Cybersecurity & Privacy Group, will participate as panelists on the webinar, What is Reasonable Information Security? Date: Thursday, April 23, 2020 Time: 10:00 AM – 11:30 AM Pacific Time Register Now JMBM’s cybersecurity lawyers, along with a cybersecurity consultant, a…
There’s no question that this is one of the most difficult times we have faced. The turnaround from nearly full employment to 3,000,000 new unemployment claims, the sequestration of two-thirds of the population, the closing of restaurants, entertainment venues, places of worship, mass furloughs and layoffs, the elimination of the…
There’s no question that the novel Coronavirus, COVID-19, has created massive disruptions in our lives. Those of us who can work are working remotely, social distancing has become the rule of the day, and while this will end, there is no sure end date in sight. Even some things that…
Amended CCPA Regulations – Key Takeaways On February 7, 2020, the California Attorney General issued a second draft of the regulations implementing the California Consumer Privacy Act of 2018 (the “CCPA”). Interestingly, while the Attorney General had earlier stated that the final regulations would be substantially the same as the…
The FTC Speaks On January 6, 2020, the Director of the Federal Trade Commission’s (FTC) Consumer Protection Bureau published a blog post with changes to the FTC’s approach to its orders and settlements of data breach enforcement actions. One of the key elements of the report was a revision to…
CCPA: Hotel Loyalty Programs, Data Retention and the Brave New World of Privacy By Robert E. Braun This article first appeared in the Hotel Business Review and is reprinted with permission from www.HotelExecutive.com. The California Consumer Privacy Act (the “CCPA” or the “Act”) is a piece of consumer privacy legislation…
As most (but not all) business know, the California Consumer Privacy Act of 2018 (the “Act” or “CCPA”) goes into effect January 1, 2020. It is estimated that more than 500,000 companies are subject to the CCPA, many of them smaller and mid-size businesses that may not have pre-existing robust…
Complying with the California Consumer Privacy Act in 5 (more or less) Not So Easy Steps Part 5 of a Series Consumer Rights: Deletion, Do Not Sell, Non-Discrimination The California Consumer Privacy Act obligates covered businesses to disclose the categories of personal information, the sources of personal information and uses…
Complying with the California Consumer Privacy Act in 5 (more or less) Not So Easy Steps: Part 4 of a Series Verified Requests for Data The CCPA is hurtling headlong toward implementation on January 1, 2020. The Act, which is likely to be amended, perhaps substantially, in the next sixty…
Ever since the California Consumer Privacy Act (the “CCPA”) was adopted in 2018, various constituencies have lobbied for revisions. While multiple proposals were considered in the California legislature, only a few have a chance for passage and enactment. Last month, the California Senate Judiciary Committee passed several amendments to the…