Jane C. Rosen

Subscribe to Jane C. Rosen's Posts

On Wednesday, March 11, 2020, the California Attorney General released a second set of modifications (the “March Revisions”) to the proposed regulations implementing the California Consumer Privacy Act of 2018 (the “CCPA”), including substantive changes to both the initial draft regulations issued in October (the “Initial Regulations”) and the revisions published Friday, February 7, 2020…

On Friday, February 7, 2020, the California Attorney General released an amended set of proposed regulations (supplemented on February 10, 2020) implementing the California Consumer Privacy Act of 2018 (the “CCPA”), including substantial changes to the draft regulations issued in October.  While the revised regulations eliminate certain requirements that businesses found to be onerous and…

The final version of the California Consumer Privacy Act of 2018 is coming into view.

On October 10, California’s Attorney General released the long-anticipated draft regulations to implement the CCPA, and on October 12, the Governor signed into law five amendments to the CCPA passed during the 2019 legislative session.  (We previously discussed the CCPA …

California’s 2019 legislative session has drawn to a close with passage of five amendments to the California Consumer Privacy Act (CCPA) during the final days of the session.  Assuming that the bills are timely signed by the Governor before the October 13 deadline, businesses will finally have the complete version of the statute that will…

On June 24th, Senators Mark Warner (D-VA) and Josh Hawley (R-MO) introduced a bill that would require large technology companies to regularly disclose to their users and the Securities and Exchange Commission (SEC) the value of the user data they collect and monetize.  The bipartisan bill, cited as the Designing Accounting Safeguards to Help Broaden Oversight and Regulations on Data (DASHBOARD) Act, is intended to capture major online platforms such as Amazon, Facebook, Google and Twitter that offer “free” services to users while monetizing user data through targeted advertising.
Continue Reading The DASHBOARD Act – Proposed New Law Would Force Large Technology Companies to Disclose the Value of Users’ Data

On the heels of the European Union’s implementation of the General Data Protection Regulation (“GDPR”) and public outcry over the Cambridge Analytica scandal, on June 28, 2018, California enacted the most comprehensive data privacy law to date in the United States. The California Consumer Privacy Act of 2018 (the “CCPA”) was hastily passed by the…

A recent FTC settlement highlights the need for companies to oversee their service providers, with respect to both collection of personal information and data security practices.

On April 30, 2018, the U.S. Federal Trade Commission (“FTC”) announced a settlement with BLU Products, Inc. (“BLU”), a Florida-based mobile device manufacturer, resolving allegations that BLU shared sensitive consumer data with a third-party service provider in violation of BLU’s privacy policy and the FTC Act.  
Continue Reading FTC Settlement Signals the Importance of Service Provider Oversight

On January 18, the Federal Trade Commission (“FTC”) released its Privacy & Data Security Update: 2017, describing its activities in the areas of consumer privacy and data security during the past year.

The report highlights the breadth of the FTC’s enforcement actions, both under Section 5 of the FTC Act, which prohibits unfair or deceptive…