Following up on yesterday’s blog about profiling and automated decision making, we now look at guidance on data protection impact assessment (DPIA). The same guidance we discussed also directs companies to conduct a DPIA where profiling or automated decision making results in the “systematic and extensive evaluation” of an individual and decisions are made based on that evaluation that could have legal effects.
Continue Reading Assessing GDPR Guidelines Part II: Data Impact Assessments

The Article 29 Data Protection Working Party recently issued guidelines on how to handle profiling and automated decision making under the General Data Protection Regulation. Under GDPR, “profiling” means the automated collection of personal information in order to evaluate personal aspects about an individual. For example, companies may use profiling to predict individuals’ spending habits, targeting ads to individuals based on their internet browsing history. 
Continue Reading Assessing GDPR Guidelines Part I: Profiling and Automated Decision Making

Much has been written about the challenges and issues that companies will face when implementing new policies and adjusting to the obligations of the new European General Data Protection Regulation, GDPR in short. The following paragraphs will give you the gist of the new Regulation and the essential elements that you must take into consideration in your endeavors to adjust to the GDPR, which will take effect across the EU as of May 25, 2018. There is enough time for your organization to adjust, but work must start now. Our key approach in implementing new obligations and making the necessary adjustments to this new European framework for personal data collection and processing is based on two simple rules: simplicity and efficiency.
Continue Reading What You Really Need To Know About The GDPR

1. Illinois and Texas recently enacted laws regulating the collection and use of biometric information (e., information based on an individual’s biometric identifiers, such as iris scans, fingerprints, voiceprints, or facial geometry) and a number of other states, including New York and California, are considering adopting such statutes. The Illinois Biometric Information Privacy Act (“BIPA”) permits private rights of action and provides for statutory damages ranging from $1,000 to $5,000 per violation. The Texas analog, entitled Capture or Use of Biometric Identifier (“CUBI”), is enforceable only by the state attorney general and permits civil penalties up to $25,000 per violation.
Continue Reading Six Things You Need to Know Before Collecting Biometric Information

In a news conference today President Obama addressed rules and proposed regulations announced Thursday intended to help the U.S. fight tax evasion and other crimes connected to anonymous offshore companies and accounts.  The announcements come after a month of intense review by the administration following the first release of the so-called Panama Papers, millions of documents stolen or leaked from Panamanian law firm Mossack, Fonseca.  The papers have revealed a who’s who of international politicians, business leaders, sports figures and celebrities involved with financial transactions accomplished through anonymous shell corporations.
Continue Reading In Wake of Panama Papers Scandal Obama Calls for Stricter Bank Regulations, Tax Rules

On February 16, 2016, Secretary of Homeland Security Jeh Johnson announced interim guidelines and procedures for sharing cyber threat indicators under the Cybersecurity Information Sharing Act of 2015 (“CISA”). Because the guidelines are voluntary, the next question is, Should your company share information with the Government?
Continue Reading To Share or Not to Share (with the Government)? That is the Question: DHS Announces Interim Guidelines for Sharing Cyber Threat Indicators