On April 24, 2025, the UK’s Office of Communications, commonly known as Ofcom—the regulator responsible for enforcing the UK’s Online Safety Act (OSA)—issued its Protecting Children from Harm Online Statement. The statement requires online services to conduct and document a children’s risk assessment in accordance with the OSA by July 24, 2025. Services will be required to implement measures to protect children from content that is harmful to them by July 25, 2025.Continue Reading The UK’s Online Child Safety Duties Are Coming into Force: Steps to Take Now
Privacy
Utah Enacts Mental Health Chatbot Law
On March 25, 2025, Utah Governor Spencer Cox signed HB 452, which establishes new rules for the use of artificial intelligence (AI) mental health chatbots accessible to any “Utah user,” defined as, “an individual located in the state at the time the individual accesses or uses a mental health chatbot.” Digital health companies and AI chatbot providers should take note of this new law to ensure compliance with its requirements.Continue Reading Utah Enacts Mental Health Chatbot Law
Lessons from the CPPA’s $632,500 Settlement with Connected Vehicle Manufacturer
On March 12, 2025, the California Privacy Protection Agency (CPPA) announced a settlement with American Honda Motor Co. (Honda) over alleged violations of the California Consumer Privacy Act (CCPA). The CPPA investigated Honda as part of its investigative sweep into the data privacy practices of connected vehicles and related technologies, announced in July 2023. The CPPA specifically alleged, among other things, that Honda engaged in practices that made it difficult for Californians to exercise their out-opt rights and shared consumers’ personal information with ad tech service providers without proper contractual protections.Continue Reading Lessons from the CPPA’s $632,500 Settlement with Connected Vehicle Manufacturer
CPPA Votes Out Proposed Delete Request and Opt-Out Platform (DROP) Data Broker Regulations
On March 7, 2025, the California Privacy Protection Agency (CPPA) Board met to discuss its proposed data broker regulations concerning the Delete Request and Opt-Out Platform (DROP) and voted to authorize CPPA staff to advance the regulations to formal rulemaking. As mandated by the Delete Act (discussed in a previous alert), the DROP will allow California residents to submit a single request to delete all personal information held by all data brokers operating in the state via an accessible mechanism. Data brokers would be required to access the DROP for updates every 45 days and delete the personal information of any state resident that matched the data broker’s records unless a deletion exception set forth in the California Consumer Privacy Act (CCPA) applies. These regulations also follow the CPPA’s November 2024 meeting, during which CPPA staff provided an update on the development of the DROP.Continue Reading CPPA Votes Out Proposed Delete Request and Opt-Out Platform (DROP) Data Broker Regulations
Upcoming Reporting Obligations Under the EU Digital Services Act
Services subject to the EU’s Digital Services Act (DSA) will be required to publish their annual transparency report by February 16, 2025. This includes providers of hosting services, online platforms, very large online platforms (VLOP)…
Continue Reading Upcoming Reporting Obligations Under the EU Digital Services ActConsumer Protection Update: With Disruption at the Federal Level, State Attorneys General Are Likely to Loom Large
We are less than a month into the new Trump administration and are seeing an unprecedented wave of activity and major changes at federal agencies. These changes promise to bring significant disruption to the staff and negatively impact the typical activities of numerous agencies, including the nation’s consumer protection watchdog, the Federal Trade Commission (FTC). As discussed below, we expect the impact on the FTC to be significant given the rapid and aggressive moves by the new administration. And we expect state Attorneys General (AGs) to step in to fill the gap.Continue Reading Consumer Protection Update: With Disruption at the Federal Level, State Attorneys General Are Likely to Loom Large