In the recent high-profile civil class action, Frasco v. Flo Health, a California federal court issued a significant ruling partially certifying a nationwide class and California subclass of individuals who used the Flo Health mobile app. The decision highlights the growing legal complexity of class action privacy claims in the age of Big Tech and health apps. Continue Reading ›
On April 24, the Federal Trade Commission announced that it had finalized changes to its Health Breach Notification Rule - to address emerging technologies.
Specifically, the Rule was broadened to (1) apply to entities not currently subject to the Health Insurance Portability and Accountability Act, (2) clarify what a breach of security is, (3) expand notification methods, (4) impose additional requirements for the content of notifications, and (5) amend the timeframe for issuing required notifications to the FTC. Continue Reading ›
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.


