On March 27, 2024, the Cybersecurity and Infrastructure Security Agency (“CISA”) published a Notice of Proposed Rulemaking for the Cyber Incident Reporting for Critical Infrastructure Act of 2022 (“CIRCIA”), which imposes new reporting requirements for entities operating in critical infrastructure
EU confirms agreement on rules to improve working conditions of platform workers
On 11 March the Council of the EU confirmed the provisional agreement reached on the Platform Workers Directive (the Directive). The Directive aims to improve the working conditions of those who work on platforms in the gig economy and will…
Testing the tricky apps for privacy and data protection
Dealing with cert pinning and root detection
The privacy area has been white-hot lately, including litigation and investigations involving VPPA; Wiretap/Pen Register/Trap and Trace; and Opt Out Compliance. Furthermore, with the HHS updates on tracking in the HIPAA context, and…
Singapore releases New Guidelines on the Use of Personal Data in AI Systems
On 1 March 2024, Singapore’s Personal Data Protection Commission (PDPC) issued the Advisory Guidelines on the Use of Personal Data in AI Recommendation and Decision Systems (AI Advisory Guidelines). These AI Advisory Guidelines followed a public…
HHS updates online tracker guidance
On March 18, 2024, the US Department of Health and Human Services (HHS) issued an updated, 17-page Bulletin titled “Use of Online Tracking Technologies by HIPAA Covered Entities and Business Associates (the Bulletin). Our readers may recall that HHS had…
ECJ’s ruling on the interpretation of “personal data” and “joint controller” in the context of the IAB TCF Framework
On 7 March 2024, the European Court of Justice (the ECJ) published an important decision in relation to IAB Europe’s Transparency and Consent Framework (the TCF).
The judgment of the ECJ is unsurprising given previous case law on…
ICO launches a call for views on the “pay or okay” model
Earlier this week the ICO launched a call for views on the “pay or okay” business model. By way of recap, this model gives users of online services the choice to either consent to personalised advertising using their data or…
Executive Order on access to Americans’ bulk sensitive data and Attorney General proposed regulations – Part 2
Approximately at the same time as the Executive Order that we described in Part 1 was issued, the Attorney General (AG) unofficially released 90 pages of Advanced Notice of Proposed Rulemaking (ANPRM), which will become official once published in the…
Executive Order on access to Americans’ bulk sensitive data – Part 1
On February 28, 2024, the White House issued an Executive Order on Preventing Access to Americans’ Bulk Sensitive Data and United States Government-Related Data by Countries of Concern. The 17-page Executive Order pointed out that “countries of concern” could use…