California Legislature Makes Last Ditch Amendments to CCPA

The CCPA, which remains set to go into effect on January 1, 2020, was amended with no less than five Assembly bills last week. The amendments, covered below, are awaiting Governor Newsom’s signature, as is Assembly Bill 1202, which requires data brokers to register with the California Attorney General. The Governor has until October 13, […]

Are You Liable for the Data Shenanigans of Others? (Part 2 – Controllers and Processors)

In Part 1 of this post, we laid a framework for the legal landscape for American businesses and their potential for exposure to State and International law regarding data privacy, very broadly. If you missed it, and you could use a 30,000 foot view, its here. Now that you know the basics behind GDPR and […]

Are The New York Department of Health’s New Breach Notification Requirements for Healthcare Providers Actually Authorized?

Early last week, a letter from the New York Department of Health was issued to Administrators and Technology Officers in the Healthcare Industry in New York, which states, essentially, that the NYDOH has implemented a new notification protocol in the event of a data breach at a healthcare facility. The letter states “We recognize that […]

Are You Liable for the Data Shenanigans of Others? (Part 1 – A Brief Introduction to the Legal Framework)

Yes. The end. Ok, it’s not quite that cut and dry, but it is somewhat of a scary proposition. I had initially envisioned discussing vendor management in the context of “controllers” and “processors”, when it occurred to me that a lot of people don’t really know what that means or even what the GDPR is […]

What’s in YOUR Wallet?

Yesterday, Capital One announced a breathtaking breach of 100 million accounts within its system, thus compromising the private data of a significant percentage of Americans in one single incident. The scope of the breach is comparable to the Equifax breach in 2017, which Equifax had acknowledged affected 143 million Americans. The question of “how can […]

New York State of Mind

This last Thursday, July 25, 2019, lawmakers in New York enacted the cleverly named “Stop Hacks and Improve Electronic Data Security Act” (the SHIELD Act), Senate Bill 5575. While Nick Fury could not be reached for comment, I was able to cobble together some details from the new law… Following the lead of many other […]

It was just a mission statement…

Just what the world needs.  Another blog. Let me start that over. What are we doing here? This first post will be my mission statement, if you will.  My statement of intentions. So, who is this blog for? It’s mainly directed to entrepreneurs, technologists, business owners, executives, in-house counsel or really anyone trying to figure […]