The first updates to the COPPA Rule since 2013 impose new obligations for sharing children’s personal information with third parties.

By Jennifer C. Archie, Marissa R. Boynton, Michael H. Rubin, Molly O’Malley Clarke, and Elizabeth Yin

On April 22, 2025, the Federal Trade Commission (FTC or Commission) published the final amendments to the Children’s Online Privacy Protection Rule (COPPA Rule)1 in the Federal Register. The published amendments will become effective on June 23, 2025

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

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

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

Proposals grant controllers increased flexibility for automated decision-making, provided suitable safeguards are implemented.

By Fiona Maclean, Gail Crawford, Amy Smyth, and Lorenzo Meusburger

On 23 October 2024, the UK government introduced the Data (Use and Access) Bill (the Bill) to Parliament, marking a significant step in the evolution of the country’s data protection landscape. It follows previous reform attempts that lapsed after the July 2024 government change. The proposed legislation aims to reform various aspects of UK data protection law while also addressing broader initiatives related to data access and digital identity. Among its many provisions (138 Clauses, 16 Schedules and 251 pages to be precise), the Bill outlines notable changes in the realm of automated decision-making.

The Regulations, which took effect on January 1, 2025, reiterate and clarify existing requirements and introduce new ones on privacy and network data security.

By Hui Xu and Bianca H. Lee

On September 30, 2024, the PRC State Council released the finalized Regulations on Network Data Security Management (Regulations), concluding a three-year consultation process since the initial draft in 2021.

The Regulations took effect January 1, 2025, and build upon the Cybersecurity Law (CSL), Data Security Law (DSL), and Personal Information Protection Law (PIPL), which form China’s legal framework for data protection and security. The Regulations integrate common cybersecurity requirements from these laws, applying them to “network data processing activities,” which include all electronic data processed through networks.

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

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.

Businesses need to be proactive in updating their compliance measures to meet the ever-evolving set of privacy laws and regulatory expectations in 2024 and beyond.

By Michael H. Rubin, Robert W. Brown, Max G. Mazzelli, Jennifer Howes, and Sarah Zahedi

Following the notable uptick in state-level privacy laws in 2023, a wave of new comprehensive state privacy laws and state laws seeking to regulate health privacy, youth privacy, online platforms, and data brokers are set to take effect this year. While a draft federal comprehensive privacy law — the American Privacy Rights Act — aimed at harmonizing this patchwork of state laws was introduced last month, until such a law actually passes, the quickly evolving state regulatory landscape will continue to set the standards for how most businesses must handle personal information in the US.

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