On June 27, 2025, the California Civil Rights Council, which is part of the Civil Rights Department, published revised regulations to protect against employment discrimination as a result of an employer’s use of artificial intelligence (AI) and other technologies that
data retention
Two FTC complaints that over-retention of personal data violates Section 5
On January 18, 2024, the U.S. Federal Trade Commission announced a complaint and proposed consent order with InMarket Media, LLC, a digital marketing platform and data aggregator. Less than two weeks later, on February 1, the FTC announced a complaint…
$8 million penalty to NYDFS – and another case of over-retention
2024 was not a happy new year for Genesis Global Trading, Inc. (“GGT”). On January 3, 2024, the New York Department of Financial Services announced a consent order with GGT, where GGT agreed to pay NYDFS $8 million and to…
Contracting for Cybersecurity Risks: Mitigating Weak Links
Managing vendor risks includes putting pen to paper. Organizations are increasingly susceptible to risks outside their controlled IT infrastructure as they engage third-party vendors to manage online platforms and process data. Even though an organization may have little to no…
Over-retention of personal data
The declining cost of electronic data storage may have caused some company executives to conclude that retaining personal data forever is “cheap.” Perhaps the CNIL’s €1.75 million (USD $2,051,930) penalty for over-retention will lead to a different view.
The matter…