- NIS-2 has a broad extra-territorial reach, and many organizations providing digital or infrastructure services into the EU may be in scope without having assessed their position.
- Non-EU organizations (including US-based businesses) may therefore be unaware that they are in scope
Navigating New Obligations Under the CCPA’s Updated Regulations
New privacy regulations provide insights into California’s approach to ADMT, cybersecurity audits, and risk assessments, while amendments impact compliance with consumer rights obligations.
By Michael H. Rubin, Jennifer Howes, Austin Anderson, Eric Gonzalez, and Sherry Tseng
Long-awaited revisions to the California Consumer Privacy Act (CCPA) Regulations were recently approved by the California Office of Administrative Law on September 22, 2025. These revisions come after a year-long process of debate and public comment and will take effect
DOJ Data Security Program: Emerging Obligations Vary by Industry, Data Sensitivity, and Corporate Structure
DOJ emphasizes need to come into full compliance with its new rule by July 8.
By Jennifer Archie, Heather B. Deixler, Clayton Northouse, Michael Rubin, Max Mazzelli, Brianna Gordon, and Kiara Vaughn
On April 11, 2025, the US Department of Justice (DOJ) released guidance regarding its final rule, known as the “Data Security Program” (DSP). The DSP, originally issued on December 27, 2024, and effective on April 8, 2025 (with certain diligence, auditing, and
Preparing for the European Health Data Space — Opportunities and Challenges for Europe’s Digital Future
The EU regulation designed to facilitate secondary use of clinical data for research brings benefits for health research, but also poses challenges for companies.
By Deniz Tschammler, Danielle van der Merwe, Oliver Mobasser
On 5 March 2025, Regulation 2025/327 creating the European Health Data Space (the EHDS Regulation) was published in the Official Journal of the European Union and entered into force on 26 March 2025. The European Commission also published FAQs on the European Health Data Space
Kingdom of Saudi Arabia Issues New Data Transfer Risk Assessment Guidelines
The guidelines specify the requirements for data controllers to conduct risk assessments related to the transfer or disclosure of personal data outside the Kingdom.
By Brian Meenagh, Calum Docherty, Faisal Imam,* and Ksenia Koroleva
The Saudi Data & Artificial Intelligence Authority (SDAIA) has released non-binding guidelines for assessing risks when transferring or disclosing personal data outside the Kingdom (the Guidelines). The Guidelines supplement the updated Regulations on Personal Data Transfer Outside the Kingdom (the Regulations), which were
Personal Data: A Relative Concept?
Advocate General Spielmann opines that personal data can be pseudonymous in the hands of one party and anonymous in the hands of another.
By Gail Crawford, Fiona M. Maclean, Myria Saarinen, Tim Wybitul, Isabelle Brams, and Amy Smyth
Advocate General Spielmann (AG) has published his Opinion in the Court of Justice of the European Union (CJEU) case C-413/23 EDPS v. SRB (Opinion), considering various questions on the scope of personal data regulated by the EU
EDPB Issues Guidelines on Processing Personal Data for Legitimate Interests Purposes
The draft guidelines provide further clarification to the EDPB’s interpretation of legitimate interests, and suggest a potential divergence with the UK ICO.
By Gail Crawford, Fiona Maclean, Myria Saarinen, Tim Wybitul, Alice Brunning, and Calum Docherty
On 8 October 2024, the European Data Protection Board (EDPB) released draft Guidelines 1/2024 (the Guidelines) setting out its approach to processing personal data based on the “legitimate interests” legal basis in Article 6(1)(f) of the GDPR. The Guidelines
UK-US Data Bridge: Practical Tips for Implementation and Compliance
Considerations for UK and US companies that are already or considering relying on the UK-US Data Bridge for personal data transfers.
By Fiona M. Maclean and Clayton Northouse
Latham & Watkins and Privacy Laws & Business recently co-hosted a webinar looking back on the first eight months since the UK-US Data Bridge entered into force. Speakers from the UK Information Commissioner’s Office (ICO) and the US Privacy and Civil Liberties Oversight Board joined the panel for a broad discussion on the practical implementation and future outlook of the UK-US Data Bridge.
Below are key takeaways from the discussion and practical tips for UK and US organisations relying on the UK-US Data Bridge to facilitate personal data transfers to the US from the UK (and Gibraltar) while ensuring data is protected consistent with the standard imposed by UK law.
EU AI Act: Navigating a Brave New World
The Act establishes the world’s first comprehensive regulatory framework for AI, and is expected to shape the future of AI regulation and governance both within and beyond the EU.
By Elisabetta Righini, Hanno F. Kaiser, Tim Wybitul, Fiona M. Maclean, and Michael H. Rubin
After three years of legislative debate, the Council of the European Union cast its final vote on the European Union (EU) Artificial Intelligence (AI) Act on 21 May 2024. Once published in
UK ICO Unveils New Fine Calculation Guide for Data Protection Infringements
Understanding the ICO’s approach to assessing financial penalties should be a key element of an organisation’s data protection strategy and risk profile.
By James Lloyd and Sami Qureshi
In an era when data protection infringements can tarnish business reputations overnight, understanding the financial ramifications is more crucial than ever. The UK’s Information Commissioner’s Office (ICO) recently unveiled its much-anticipated updated guidance on the calculation of fines for data protection infringements under the UK General Data Protection Regulation (UK GDPR) and