Tag Archives: PII

Are You Prepared for Your Vendor’s Data Breach?

Ever since the Target and Home Depot breaches were traced to intrusions at their vendors, the management of cybersecurity at third-party vendors has been a focus of companies and regulators. The FTC has flagged the issue, as has the SEC. The DoD has imposed strict cybersecurity requirements for contractors that “flow down” to sub-contractors. But despite an … Continue Reading

CalOPPA Enforcement Grounded, For Now

This post was also written by Joshua B. Marker and Tyler M. Layton. In a significant victory, Delta Airlines’ demurrer to the enforcement action filed by the state of California was sustained without leave to amend. We previously wrote about the case here. California alleged that Delta’s mobile application was in violation of CalOPPA because its … Continue Reading

CA Legislators Demand the Right To Be Forgotten (Quickly): Bill Targets Social Media

This post was also written by Joshua B. Marker. California continues to be among the most aggressive states in proposing legislation restricting disclosure of personal identifying information. Earlier this month, California Senate Majority Leader Ellen M. Corbett (D) introduced SB 501, known as the Social Networking Privacy Act, which would require social networking websites to remove certain … Continue Reading

California’s Proposal to Require Privacy Policies Be No More Than 100 Words: Simplifying or Complicating the Process?

This post was also written by Frederick Lah. A California state assemblyman proposed legislation this week attempting to require that online privacy policies be no more than 100 words. The legislation would also require that the privacy policy “be written in clear and concise language, be written at no greater than an 8th grade reading level, … Continue Reading

California Mobile Privacy Enforcement Takes Flight; All Companies Offering Mobile Apps to Consumers Should Prepare for Landing

This post was also written by Joshua Marker. Following a year in which she repeatedly announced her intention to make mobile privacy a priority, California Attorney General Kamala Harris filed the first mobile privacy enforcement action against Delta Air Lines. The case, The People Of The State Of California v. Delta Air Lines, CGC-12-526741, filed … Continue Reading

Judge Rules IP Address Does Not Identify User

This post was also written by Chris Cwalina and Frederick Lah. In VPR Internationale v. Does 1-1017 (C.D. Ill.), Judge Baker opined that Internet Protocol (“IP”) addresses do not — by themselves — qualify as personal information, capable of accurately identifying an individual. While this decision is a landmark ruling for the mass-BitTorrent lawsuits in … Continue Reading

Privacy: A Washington Tale of Two Reports

This post was also written by Chris Cwalina and Amy Mushahwar. We’ve been busy here in Washington with two seminal privacy reports released within a span of two weeks.  At Reed Smith, our interdisciplinary team of former government officials, former in-house attorneys, class action litigators and engineers (in the US and internationally) are reviewing the releases … Continue Reading

FTC Releases Privacy Report

This post was also written by Christopher G. Cwalina, Amy S. Mushahwar, and Frederick Lah. On December 1, 2010 the FTC released its long-awaited Protecting Consumer Privacy in an Era of Rapid Change. This 123-page preliminary staff report proposes a sea change in US privacy law. The FTC is accepting comments on this report until January … Continue Reading
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