When thinking about privacy notice obligations, companies often -incorrectly- leap to the wording in their privacy policies. The new comprehensive state privacy laws are a reminder that notice obligations are a bit broader than mere privacy policies. To the extent that these laws apply to your organization (see our prior applicability post) there are some notice-related obligations to keep in mind.Continue Reading The Comprehensive Privacy Law Deluge: Approaching Notice Obligations
Of the many worries on privacy compliance teams’ lists as we face the onslaught of state “general” privacy laws are the impacts they have on vendor contracts. Fortunately for those who have already had to deal with contracts with vendors (service providers, processors) in California or EU’s GDPR, the impact should be fairly minimal.Continue Reading The Comprehensive Privacy Law Deluge: Updating Vendor Contracts
With a little less than a week before the next US state “comprehensive” privacy laws (Colorado and Connecticut) go into effect, many are reviewing existing practices. One that keeps coming up is the concept of “profiling.” As a reminder, we now have 11 states with comprehensive privacy laws: California, Colorado, Connecticut, Florida, Indiana, Iowa, Montana, Tennessee, Texas, Utah, and Virginia.Continue Reading The Comprehensive Privacy Law Deluge: What to Do About “Profiling”
The Connecticut governor recently signed SB 1103, bringing the state into the artificial intelligence regulation fray. The law regulates state agencies, and calls on the Department of Administrative Services to perform regular assessments of systems use by these agencies. The assessment is to identify which systems use artificial intelligence and to ensure that the use does not result in unlawful discrimination or disparate impacts. The systems inventory must be conducted by December 31 of this year, and the assessment by February 1, 2024. These inventories and assessments must thereafter be conducted on an annual basis.Continue Reading Connecticut Enters AI Fray