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Brandon Robinson is a partner at Balch & Bingham. He counsels clients in a wide variety of industries regarding cybersecurity and data privacy issues to assist them in proactively managing risks while maintaining innovative customer service.

On May 19, 2022, the Federal Trade Commission voted 5-0 to adopt a policy statement regarding increased scrutiny of the Children’s Online Privacy Protection Act (COPPA) violations involving education technology companies.  The statement reaffirmed COPPA provisions around limiting educational technology’s collection, use, retention and security requirements for children’s data. The FTC stated:

“When Congress enacted

In November 2021, non‑state issued digital assets reached a combined market capitalization of $3 trillion, up from approximately $14 billion in early November 2016.  Several global monetary authorities are exploring, and in some cases introducing, central bank digital currencies (CBDCs).  On March 9, 2022, President Biden issued an executive order to mandate multiple reports and

On December 20, 2021, The National Institute of Standards and Technology (NIST) released its draft interagency report 8403 on “Blockchain for Access Control Systems”.  As the report’s abstract states:

“Protecting system resources against unauthorized access is the primary objective of an access control system. As information systems rapidly evolve, the need for advanced access control

On November 18, 2021, the Federal Reserve, Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) approved a new final rule regarding reporting of cyber incidents for U.S. banks and service providers.

Under the new rule, a banking organization must notify its primary federal regulator of “any significant computer

A new bill introduced by the Senate (S. 2666), the “Sanction and Stop Ransomware Act of 2021”, would require a strict 24-hour limit for reporting ransomware payments for businesses with more than 50 employees. The bipartisan bill, put forward by leaders of the Senate Homeland Security and Governmental Affairs Committee, also focuses on critical infrastructure,

Background

Yesterday, on September 22, 2021, the California Privacy Protection Agency (“CPPA”) — the new privacy regulatory agency created by the California Privacy Rights Act of 2020 (“CPRA” or “CCPA 2.0”) — issued an invitation for public comment on its proposed rulemaking.  Such comments “will assist the Agency in developing new regulations, determining whether

Background

On August 30, 2021, the Securities and Exchange Commission (SEC) sanctioned eight firms in three actions for cybersecurity failures in their policies and procedures that exposed the personal information of thousands of customers at each firm. These firms included: Cetera Advisor Networks LLC, Cetera Investment Services LLC, Cetera Financial Specialists LLC, Cetera Advisors LLC,

On March 17, 2021, Governor Gavin Newsome, Attorney General Xavier Becerra, Senate President pro tem Toni Atkins, and Assembly Speaker Anthony Rendon announced the members of the California Privacy Protection Agency (CPPA) the new administrative agency created by the California Privacy Rights Act (CPRA) charged with protecting consumer privacy rights overs personal information.

“Californians deserve

California Attorney General Issues Additional CCPA Regulations Advancing Consumer Protections

On March 15, 2021, the California Attorney General (“AG”) approved additional CCPA regulations to enhance consumer protections for opting out of the sale of information.  These regulations come after the third set of modifications was approved last October, and after the California Privacy Rights Act

As the nation closely watches the election results coming in, the majority of votes counted in California suggest that the California Privacy Rights Act of 2020 (“CPRA”, or commonly known as “CCPA 2.0”), is on track to pass.  Proposition 24 under the California General Election, as of the information available to us at the time