U.S. State Privacy Laws
Nuanced comprehensive consumer privacy laws have been enacted in the U.S. by state legislatures, with more to come. Understanding their similarities, differences, and interactions with other laws, as well as the accompanying regulatory environment, is no small task. Sidley provides insight and perspective. You will also find our convenient tables and a map providing effective dates of the statutes and their amendments. Our Privacy and Cybersecurity lawyers also regularly contribute state law developments to the Sidley AI Monitor.
Illinois Supreme Court Clarifies Accrual for Illinois Biometric Privacy Act Claims
For the second time in two weeks, the Illinois Supreme Court clarified the scope of the Illinois Biometric Privacy Act (BIPA) — this time in Cothron v. White Castle. The court, in a 4–3 decision, held that BIPA claims accrue each time biometric data is collected or transmitted, and not just the first time.1
(more…)
Kathleen Carlson
Chicago
kathleen.carlson@sidley.com
Lawrence P. Fogel
Chicago
lawrence.fogel@sidley.com
Geeta Malhotra
Chicago
gmalhotra@sidley.com
Stephen W. McInerney
Chicago
smcinerney@sidley.com
Vera M. Iwankiw
Andrew F. Rodheim
Chicago
arodheim@sidley.com
NY DFS Proposes New Class of Entities and More Detailed Regulations in Second Amendment to Cybersecurity Regulations
On November 9, 2022, the New York Department of Financial Services (DFS) published its proposed second amendment to its cybersecurity regulations (23 NY CRR Part 500). This proposal follows a July 29 pre-proposal and comment period. The amendment is available for a sixty-day comment period – until January 9, 2023 – after which the agency may adopt final regulations or issue a further revised version.
(more…)
Alan Charles Raul
Washington, D.C., New York
Colleen Theresa Brown
Washington, D.C.
cbrown@sidley.com
Vishnu Tirumala
Washington, D.C.
vtirumala@sidley.com