On April 4, 2025, the California Privacy Protection Agency (CPPA) Board met to discuss the latest draft California Consumer Privacy Act (CCPA) regulations related to cybersecurity audits, risk assessments, automated decision-making technology (ADMT), and an assortment of other updates to existing regulations. These revisions come after the CPPA first released draft regulations on these topics in July 2024 and initiated the formal rulemaking in November 2024, as analyzed in a prior alert. The board meeting turned out to be quite contentious, with board member Alastair Mactaggart emphasizing some of the serious concerns raised in the unusually large volume of public comments—totaling 630 comments and 1,664 pages of feedback—expressing his own concerns that those comments lay out “the very explicit blueprints” for others to challenge the constitutionality of the draft regulations. Ultimately, the Board provided extensive feedback on the draft regulations to CPPA staff, going beyond the issues that staff had prepared for discussion.Continue Reading CPPA Board Grapples with Public Concerns: Key Updates on Upcoming AI, Risk Assessment, and Cybersecurity Regulations
Cybersecurity
UK Regulator Issues Three Million GBP Monetary Penalty in Connection with Ransomware Attack
On March 27, 2025, the Information Commissioner’s Office (ICO) announced a fine of 3 million GBP (3.9 million USD) against a software provider (the company) for security deficiencies following a ransomware incident (e.g., lack of multi-factor authentication (MFA)). This is the first time the ICO has fined a processor under the UK’s General Data Protection Regulation (GDPR). This post provides an overview of the decision and outlines the key points companies should consider, including the security measures the ICO expects them to implement.Continue Reading UK Regulator Issues Three Million GBP Monetary Penalty in Connection with Ransomware Attack
EU Data Act Imposes New Data Sharing Obligations
As of September 12, 2025, the EU Data Act will impose new obligations concerning the sharing of, and access to, data generated by certain products and services offered in the EU. This alert highlights the data sharing obligations for providers of connected devices and related services.Continue Reading EU Data Act Imposes New Data Sharing Obligations
EU Commission Issues Guidelines on Prohibited AI Practices Under EU AI Act
On February 4, 2025, the European Commission (EC) issued draft guidelines clarifying the AI practices that are prohibited under the European Union’s (EU) Artificial Intelligence (AI) Act. While non-binding, the guidelines offer valuable clarifications and practical examples to help businesses navigate their obligations under the AI Act. The EC has approved the draft guidelines, but is still to formally adopt them, which is expected in the near term.Continue Reading EU Commission Issues Guidelines on Prohibited AI Practices Under EU AI Act
Understanding the EU’s Cyber Solidarity Act: Key Takeaways
On February 4, 2025, the European Union’s (EU) Cyber Solidarity Act (CSA) entered into force. The CSA aims to harmonize and strengthen the cooperation between EU authorities to improve their capacity to detect and address…
Continue Reading Understanding the EU’s Cyber Solidarity Act: Key TakeawaysThe EU’s AI Act Starts to Apply as of February 2, 2025
On February 2, 2025, the European Union’s (EU) Artificial Intelligence Act (AI Act) will start to apply in phases. This alert summarizes the new obligations that will apply as of February 2, 2025. It also indicates when companies can expect the first enforcement actions, and what the enforcement regime will look like. For more information about the scope and requirements of the AI Act, please see our 10 Things You Should Know About the EU AI Act.Continue Reading The EU’s AI Act Starts to Apply as of February 2, 2025