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Work in Progress: Substantial Revisions Recommended to the European Commission’s Draft New Standard Contractual Clauses

Last week, the European Data Protection Board (“EDPB”) and the European Data Protection Supervisor (“EDPS”) published a joint opinion on the European Commission’s (“EC”)…

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Cranking up the Pressure: Federal Financial Regulators’ Proposed Rule on Computer-Security Incident Notification and How it Could Impact Banks, Fintech Firms, and Other Bank Service Providers

From California to Europe, the final months of 2020 featured several high-profile developments in the privacy and data security fields. One development that…

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HIPAA for the Holidays: How OCR’s December HIPAA Notice of Proposed Rulemaking Could Impact Covered Entities

In case privacy lawyers did not have enough to keep up with over the holiday season (as we’ve mentioned, there’s already plenty to keep up…

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Schrems II: What About US-Based Organizations with Consumer-Facing Websites and Apps? (Part 1 of 2)

In its Schrems II decision, the Court of Justice of the European Union (“CJEU”) created a major headache for transatlantic trade when it invalidated…

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No Silver Linings: EDPB Issues a Grim Forecast on U.S.-Based Cloud and Data Access with New Guidance

On November 10, 2020, the European Data Protection Board (“EDPB”) issued highly anticipated guidance intended to clarify how data exporters could legally transfer data…

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