On August 25, 2017, the Cyberspace Administration of China (“CAC”) issued the Administrative Provisions for Services concerning Internet Comment Posting (the “Internet Comment Posting Provisions”) and the Administrative Provisions for Services concerning Internet Forums and Communities (the “Internet Forum and Community Services P… Continue Reading
On Tuesday, August 1, 2017, a bipartisan group of four Senators from the Senate Cybersecurity Caucus introduced legislation designed to improve the cybersecurity of devices purchased by the U.S. government and – albeit indirectly – sold anywhere in the U.S. or the world.
The legislation – the “Internet of Things (IoT) Cybersecurity Improvemen… Continue Reading
Ample bandwidth has been eaten by panicky commentary over the fines possible under the EU’s upcoming General Data Protection Regulation (GDPR). Sure, the GDPR arms EU data protection authorities with a hefty compliance stick. Yet the focus on exorbitant fines seems a bi… Continue Reading
On June 10, 2017, the Cyberspace Administration of China (the “CAC”) released the Draft Regulations on the Security Protection of Critical Information Infrastructure (the “Draft Regulations” 《关键信息基础设施安全保护条例（征求意见稿）》). The CAC is seeking public comments with a deadline of August 10, 201… Continue Reading
The Federal Communications Commission (FCC) marked another step in its effort to curtail illegal robocalls. During its recent Open Meeting, the FCC approved Notices of Inquiry (NOIs) into Call Authentication methods and into Advanced Methods to Target Unlawful Robocalls that, respectively, seek input on efforts to institute a caller ID-based “Tru… Continue Reading
The Federal Trade Commission (“FTC”) recently issued an updated “Six-Step Compliance Plan for Businesses” (“Compliance Plan”) for entities subject to the Federal Children’s Online Privacy Protection Act (“COPPA”), 15 U.S.C. §§ 6501-6506, to “reflect developments in the marketplace—for example, the introduction of int… Continue Reading
The digital marketing industry is powered by information about individuals (“personal data”) that pulses through a supply web. As this FTC infographic shows, some industries such as retail, energy, financial services, and health care, have direct relationships with those individuals. Other industries, such as data marketing, generally are at l… Continue Reading
In a recent order, the FCC has reinstated its customer proprietary network information (“CPNI”) rules governing the privacy obligations of voice service providers under Section 222. This action follows the Congressional repeal of the FCC’s 2016 Privacy Order that had extended CPNI regulations to broadband internet access services. As a result… Continue Reading
As a reminder that state attorneys general have enforcement authority over breach notifications, the New York Attorney General recently announced a $130,000 settlement for a failing to provide breach notification in a reasonable time. Organizations should ensure that they are prepared to quickly provide required notifications in the event of a breac… Continue Reading
On June 7, 2017, the Canadian government announced that it is suspending indefinitely the private right of action provided for by Canada’s Anti-Spam Legislation (“CASL”), which sets forth the country’s regime of disclosures, consent, and unsubscribe requirements for commercial electronic messages and installation of computer programs, w… Continue Reading
On May 11, 2017, the White House released its long-awaited Executive Order on cybersecurity (EO). The EO directs Executive Branch agencies to develop plans to assess and improve the cybersecurity of their own operations, based on the 2014 NIST Cybersecurity Framework; directs law enforcement and national security agencies to work with providers of cri… Continue Reading
On Monday, April 3, President Trump signed a bill repealing the privacy and security rules introduced in the FCC’s October 2016 Order. Under the terms of the Congressional Review Act (CRA), those rules have now been entirely repealed, the FCC is restricted from implementing “substantially similar” rules in the future, and the congressional act… Continue Reading
On Wednesday, the Chairman Pai-led FCC adopted an Order granting a stay of the data security rules that were adopted as part of the Commission’s 2016 Privacy Order spearheaded by former FCC Chairman Wheeler. The stay will maintain the data security rules that have been in place for several years, but suspend implementation of the expanded data security r… Continue Reading
On Friday, the Federal Register published the FCC’s January 17th Public Notice of the fact that eleven Petitions for Reconsideration were filed in the Broadband Privacy proceeding (WC Docket No. 16-106). The Petitions challenge various aspects of the FCC’s new ISP privacy regime, and were filed by ISP and cable trade groups as well as by advertiser… Continue Reading
FCC Issues Clarification of Broadband Privacy Rules Deadlines
Today, FCC Chairman Tom Wheeler confirmed that he will resign effective January 20, 2017, Inauguration Day. With Commissioner Rosenworcel unlikely to be confirmed for a new term, this would leave the FCC with two Republicans (Commissioners Pai and O’Rielly) and one Democrat (Commission… Continue Reading
Notice, Choice, and Prospects in the New Administration
The FCC adopted new privacy and security rules for telecommunications carriers—including ISPs—on October 27. In this second of two webinars in DWT’s series examining the rules, DWT experts analyzed the core Notice and Choice rules’ requirements, provided perspectives on differences w… Continue Reading
DWT experts in the privacy and communications fields walked through the answers step-by-step in the first of two webinars examining the FCC’s privacy regime in-depth. We described the
- phase-in schedule for the rules
The FCC’s new privacy rules were published in the Federal Register last Friday, December 2, 2016. The publication of these rules initiates the period in which broadband ISPs must come into compliance with the agency’s sweeping new rules.
Following the approval of the FCC’s new privacy rules on October 27, ISPs need to address a number of issues, including opt-ins and opt-outs as well as information security programs. To help you prepare, the DWT team has prepared a two-part webinar series.
FCC Privacy Rules, Part 1: Plan… Continue Reading
On Nov. 2, 2016, the FCC released its long-awaited broadband privacy Order and rules by a 3-2 vote. The Order comes nearly 18 months after the Commission moved to reclassify broadband internet access service (“BIAS”) as a common carrier telecommunication service under Title II of the Communications Act, and over the strenuous dissent of both Republi… Continue Reading
The FTC Issues Guidance on How to Batten Down the Hatches
The Federal Communications Commission released the full text of its anticipated privacy rules for internet service providers (ISPs), telecommunications carriers, and interconnected VOIP providers.
Broadly speaking, these rules require covered providers to:
- notify customers of their uses of data;
- permit customers to opt-in to uses of sensitive da
DWT is committed to providing the latest updates on the FCC’s privacy rules. Please see our special blog post series on the FCC’s new privacy rules.
Today, the FCC formally adopted on a 3-2 party-line vote an order that enacts a new privacy and security regime for Internet service providers (ISPs). While it may be several days before the official orde… Continue Reading