• Posts by Sarah Rugnetta
    Partner

    Sarah serves as a vice chair of the Constangy Cyber Team and practices in New York. She leads the provision of compliance advisory services for the Cyber Team, advising clients on strategies to mitigate risk associated with data ...

On Monday, the U.S. Department of Health and Human Services Office for Civil Rights issued updated guidance on the use of online tracking technologies by covered entities and business associates (here, referred to as “regulated entities”) under the Health Insurance Portability and Accountability Act Privacy Rule. The intent of the guidance is to provide regulated entities with considerations when using tracking technologies on their websites and mobile applications.

Last week, the California Attorney General announced its second-ever settlement under the California Consumer Privacy Act, as amended by the California Privacy Rights Act. The settlement was with the online food ordering and delivery platform DoorDash.

The New York Department of Financial Services recently amended its Cybersecurity Regulation. The revisions aim to strengthen cybersecurity and technology controls to address evolving threats to consumer data and ensure the continued integrity of financial systems. Here are a few key elements of the amendments to Regulation and what we think will be their immediate impact on financial institutions.

Oregon will soon join Iowa, Indiana, Florida, Montana, Texas, and Tennessee in passing a comprehensive data privacy law. On June 25, the Oregon legislature passed the Oregon Consumer Privacy Act. The OCPA has moved to the desk of Gov. Tina Kotek (D), who is expected to sign it into law. Assuming she does, the law will take effect on July 1, 2024.

The Constangy Cyber Advisor posts regular updates on legislative developments, data privacy, and information security trends. Our blog posts are informed through the Constangy Cyber Team's experience managing thousands of data breaches, providing robust compliance advisory services, and consultation on complex data privacy and security litigation. 

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