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$10,000,000 civil penalty for disclosing personal data without consent

Data Protection Report

that “uses cookies, pixel tags, and other storage and tracking technology to collect or receive information from [Cerebral’s] [w]ebsites and [a]pps based on [consumers’] usage activity.” The complaint alleged that the company’s data handling practices also resulted in unauthorized disclosures of personal information.

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Historic Charges: First Enforcement Action Filed by New York Department of Financial Services Under Cybersecurity Regulation

Data Matters

4 The Regulation sets minimum standards for compliance related to the assessment of cybersecurity risks, the prevention and detection of security events, and post-breach management. implement controls, including encryption, to protect NPI held or transmitted both in transit over external networks and at rest (23 NYCRR § 500.15).

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US: The CCPA ‘Moving Target’ One Month Before Privacy Enforcement Begins

DLA Piper Privacy Matters

Second, focus your available resources on finishing compliance with CCPA statutory privacy requirements, and equally important, on ensuring that you have adequately remediated CCPA “reasonable security” class action risk. Doing any of these things avoids the obligation even to notify of the breach, and so avoids even potential claims.

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