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[…] lowest numerical applicability thresholds of any of the state comprehensive privacy laws when the law was enacted in 2023. At that time, prior comprehensive privacy laws in Virginia, Colorado, Utah, Connecticut, Iowa, and Indiana all applied to controllers that either (1) control or process the personal data of at least 100,000 consumers (“the general […]

[…] small or if keys are compromised. Secure implementation requires strong, unique salts per record and careful key management. Pseudonymization: As defined earlier, identifiers are replaced with artificial codes or pseudonyms. The link between the pseudonym and the real identity is maintained (often separately), allowing potential re-identification. k-Anonymity: This is a formal privacy model, not […]

[…] like “personal information” and “operator,” but in a few instances switches to “personal data” and “controller,” perhaps from borrowing language from more modern privacy laws like the Virginia Consumer Data Protection Act.     The substantive data minimization trend continues While the federal COPPA framework is largely focused on consent, former Commissioner Slaughter noted in 2022 […]

Thank you for the contributions of Rob van Eijk, Marlene Smith, and Katy Wills We are now in 2025, the year of AI agents. In the last few weeks, leading large language model (LLM) developers (including OpenAI, Google, Anthropic) have released early versions of technologies described as “AI agents.” Unlike earlier automated systems and even […]

[…] annually on January 28 to mark the anniversary of Convention 108, the first binding international treaty to protect personal data. To raise awareness for the day and promote best practices for data privacy, we’ve partnered with Snap to create a Data Privacy Day Snapchat Lens that lets you choose what type of privacy pup […]

[…] fragmentation of the cross-border data transfer landscape globally and in APAC into clusters of likeminded jurisdictions, ranging from those like Singapore and Japan that are working to promote trusted data flows (especially through initiatives like the Global CBPRs) to those like Indonesia, India, and Vietnam that have recently renewed their interest in adopting data […]

[…] AI legislation. Maryland passed the  Maryland Online Data Privacy Act (MODPA) as well as the Maryland Age-Appropriate Design Code Act” (Maryland AADC).  Following Connecticut’s lead last year, Virginia and Colorado both amended their state privacy laws to add specific online protections for kids’ data. FPF also examined genetic privacy laws from Montana, Tennessee, Texas, […]