On February 8, 2024, the French data protection authority (CNIL) published a list of its enforcement focus areas for 2024.[1] The CNIL will focus on the processing of children’s data by online services, the handling of individuals’ requests to access their personal data (so-called “DSAR”), the re-use of data processed for loyalty programs, and data processed in connection with the upcoming Olympic and Paralympic games.Continue Reading French Data Protection Authority Publishes Its 2024 Enforcement Focus Areas

On February 2, 2024, a committee of ambassadors from all countries of the European Union (EU) approved the latest draft of the EU Artificial Intelligence Act (AIA or the Act). Following weeks of speculation that there could be a blocking minority of EU countries who had concerns about the final text, this vote confirms that the AIA has substantial support within the Council of the EU (Council). This means that the AIA has a good chance to become law within the coming months. For more information about the scope and requirements in the AIA, please see our client alert on last December’s political agreement on the AI Act, available here.Continue Reading The AI Act Just Got One Step Closer to Becoming Law

In 2024, businesses will continue to face an evolving landscape of privacy opportunities and challenges, including an increasingly complex data regulatory environment that extends beyond the General Data Protection Regulation (GDPR). With heightened scrutiny from regulators, consumers, and investors, the need to bolster privacy and data management practices has become even more important. Here’s our top 10 list of what to watch for in the privacy and data regulatory space in 2024:Continue Reading 10 Privacy Predictions in the EU for 2024

2023 was one of the busiest years for privacy yet—with more to come in 2024. Five new U.S. state privacy laws (in Texas, Florida, Oregon, Montana, and Washington) will come into effect in 2024. And federal and state regulators are sure to focus on hot areas like artificial intelligence, children’s privacy, and the collection, use, and sharing of consumer health data, among others. Given this backdrop, here are our top 10 predictions for privacy regulation in 2024:Continue Reading U.S. Privacy Predictions: What to Watch for in 2024

On December 8, 2023, the California Privacy Protection Agency (CPPA) Board discussed a draft of its forthcoming artificial intelligence (AI) regulations on automated decision making technology (ADMT). The proposed regulations, published earlier on November 27, 2023, would impose significant new requirements on businesses subject to the California Consumer Privacy Act (CCPA) that use ADMT for certain use cases. The ADMT draft rules are expected to be part of the Agency’s larger rulemaking package alongside rules governing cybersecurity audits and risk assessments under the CCPA, as amended by the California Privacy Rights Act. While the draft ADMT regulations currently have no legal effect and are likely to undergo further revision before formal rulemaking begins, the current draft nonetheless provides an important preview of the rigorous new compliance requirements that could later take effect. Notable items put forth for public discussion include:Continue Reading Draft California AI Regulations Become One Step Closer to Reality: An Analysis of Requirements on the Horizon