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[…] laws with duties of care to avoid heightened risk of harm. That’ s a model adopted in Connecticut, Colorado, and now Montana. There’ s the Age-Appropriate Design Code model under consideration in several states and enacted in California and Maryland. There is also significant ongoing litigation over age verification requirements, resulting in injunctions across […]

[…] to them upon request. The CFPB undertook a lengthy and extended process to issue these rules, and engaged with numerous stakeholders and closely monitored market developments to promote consumer interests, innovation, and competition. Ms. Strickland’s testimony lists a number of valuable aspects to the rule, including its treatment of consumer controls, screen scraping, security […]

[…] for the Required Rulemaking on Personal Financial Data Rights . As part of this process, the CFPB engaged with numerous stakeholders and closely monitored market developments to promote consumer interests, innovation, and competition. Engagement included meetings with stakeholders, such as FPF. Meetings that occurred during the rulemaking process were captured as ex parte conversations […]

Today, the Future of Privacy Forum (FPF) published a new paper—Data Minimization’s Substantive Turn: Key Questions & Operational Challenges Posed by New State Privacy Legislation. Data minimization is a bedrock principle of privacy and data protection law, with origins in the Fair Information Practice Principles (FIPPs) and the Privacy Act of 1974. At […]

Today, the Future of Privacy Forum (FPF) published a new paper—Data Minimization’s Substantive Turn: Key Questions & Operational Challenges Posed by New State Privacy Legislation. Data minimization is a bedrock principle of privacy and data protection law, with origins in the Fair Information Practice Principles (FIPPs) and the Privacy Act of 1974. At […]

In May 2025, Nebraska and Vermont passed Age-Appropriate Design Code Acts (AADCs), continuing the bipartisan trend of states advancing protections for youth online. While these new bills arrived within the same week and share both a common name and general purpose, their scope, applicability, and substance take two very different approaches to a common goal: crafting a design […]

In May 2025, Nebraska and Vermont passed Age-Appropriate Design Code Acts (AADCs), continuing the bipartisan trend of states advancing protections for youth online. While these new bills arrived within the same week and share both a common name and general purpose, their scope, applicability, and substance take two very different approaches to a common […]

[…] the IAPP Global Privacy Summit 2023 in Washington, D.C. The IAPP Leadership Award is given annually to individuals who “demonstrate an ongoing commitment to furthering privacy policy, promoting recognition of privacy issues, and advancing the growth and visibility of the profession.” 21 ANNUAL REPORT 2023 Members of the FPF Advisory Board receive increased engagement […]

[…] impact on, a minor; (b) financial, physical, or reputational injury; (c) unauthorized disclosure of personal data as a result of a security breach (as described in Mont. Code Ann. § 30-14-1704); or (d) intrusion upon the solitude or seclusion or private affairs or concerns of a minor, whether physical or otherwise, that would be offensive […]

[…] the advancement of science and healthcare improvements which are accomplished with de-identified data. Properly implemented de-identification complying with the HIPAA de-identification provisions goes a long way toward promoting such a reasonable balance, but I would suggest that there is still room for further improvements in this regard. Where Should We Go From Here? Perhaps […]