Welcome back to our two-part series examining CNIL vs. Google: 10 lessons from the largest data protection fine ever issued. In this post we continue our analysis of CNIL vs. Google by taking a closer look at the additional lessons we can learn from this important decision.
6. …tell data subjects exactly what you’re doing
CNIL vs. Google: 10 lessons from the largest data protection fine ever issued
In January 2019, the French data protection authority, CNIL (Commission Nationale de l’informatique et des libertés), announced that it had fined Google 57 million euros (approximately £44 million or USD$65 million) for breaching the EU’s General Data Protection Regulation (GDPR) through its use of targeted advertising.
The fine arose out of complaints made against Google
Recent Developments on the California Consumer Privacy Act (CCPA)
The California Attorney General is currently on a California tour soliciting public comment on the CCPA.[i] To date, the Attorney General has held public forums in San Francisco (January 8th), San Diego (January 14th) and Riverside (January 24th) and will continue on to Los Angeles (January 25th), Sacramento (February 5th), and Fresno (February 13th).
Workplace Monitoring: Where Do Employers Draw The Line?
Recent developments in privacy law and a rise in class action lawsuits related to data collection offer a cautionary tale about understanding legal and ethical boundaries of monitoring “on-the-clock” employee conduct. With a hodgepodge of federal, state, and local legislation governing employee privacy rights, employers are often left to navigate a complicated legal landscape while balancing
SEC Report Reiterates Cybersecurity Implications for Internal Control Requirement
On October 16, 2018, the Securities and Exchange Commission (SEC) issued a report on the results of investigations made by the SEC’s Division of Enforcement into nine public companies that were victims of cyber-related frauds. In each case, the SEC investigation focused on whether the target companies had complied with the applicable requirements of the
Cybersecurity & Retirement Plans
It seems that most employees and plan participants “think” their retirement money and data are not at risk. This is due, in part, because:
- there are few published incidents of breaches or potential hacks;
- there has been not a single legal decision involving a cybersecurity breach and a retirement plan; and
- there is no comprehensive
South Carolina Requires Cybersecurity Program for Insurance Licensees
South Carolina has become the first state to enact cybersecurity legislation for the insurance industry.
On May 3, Governor McMaster signed a bill requiring South Carolina insurers to “develop, implement, and maintain a comprehensive information security program” for their customers’ data. 2017 SC H.B. 4655 (NS). Based on the insurance industry model rules, the South
Retailers, Consent and the GDPR: Is Your Business in Breach?
After 25 May 2018, data protection will be a high-risk issue for all retailers who fall within the scope of the GDPR. Organizations can be fined up to 4% of annual worldwide turnover or 20 million euros (whichever is greater) for violations of the GDPR. Moreover, the GDPR applies to any business that targets
Federal Enforcement Isn’t the Only HIPAA Concern—States Flex Their Muscles
Despite the lack of significant settlements for HIPAA enforcement by the federal Office of Civil Rights (OCR) so far in 2018, states have not hesitated to patrol privacy and security breach activity and take action against perceived violations. Indeed, under the HITECH Act, state attorneys general have their own HIPAA enforcement authority. Two recent settlements
HIPAA in Due Diligence (Part III): Risk Mitigation Strategies
Health Information Highlight
Welcome back to our three-part series examining ways to efficiently identify, address and mitigate gaps in HIPAA compliance in transaction diligence. In Part I, we discussed four key diligence questions upon which buyers should focus their efforts in a transaction. In Part II, we reviewed considerations related to storage of and access