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Robert Cunningham

What Constitutes a “Sale” of Privacy Information under CPRA/CCPA?

The California Consumer Privacy Act (CCPA) that went into effect on January 1, 2020 and the recently approved California Privacy Rights Act (CPRA) that will supersede CCPA come 2023, are applicable to any for-profit business in California that meets any one of the following thresholds: Annual gross revenue in excess of $25 million Buying, receiving […]

Are You Complying with CPRA/CCPA Opt-Out Rights?

Under the California Consumer Privacy Act (CCPA) that went into effect on January 1, 2020 and the recently approved California Privacy Rights Act (CPRA) that will supersede CCPA come 2023, California residents have the right to opt-out of a business selling or sharing any of their personal information. That means that if you are a […]

GDPR
Do You Have a “Legitimate Interest” in the Data You Collect?

How can organizations decide whether their interests are “legitimate,” and how are they supposed to figure out whether their interests are “overridden” by those of the data subject?

The Top 5 GDPR Compliance Mistakes and How to Avoid Them

The European Union’s General Data Protection Regulation (GDPR) is a complex and sweeping data protection law that has left companies all over the world scrambling to rethink their data handling processes.  Unfortunately, ensuring full compliance with the 88-page regulation isn’t easy. In fact, many companies are still making mistakes — and with penalties maxing out […]

A Primer on Data Privacy

What is data privacy and why does it matter? How did we get here, what does “here” look like, and what’s ahead? At a recent Ketch meetup, I presented a primer on data privacy, exploring the past, present, and future of privacy law. Below are my slides, as well as summary takeaways. Thanks to those of […]

Could Your Privacy Policy Cope With Explosive Growth?

Six months ago, Zoom was a buttoned-down, business-focused video-chat tool with 10 million daily users — but by March, its user-base had surged to over 200 million as the coronavirus pandemic drove countless organizations to move online. Almost overnight, Zoom became not just a household name but a generation-defining cultural touchstone, and its stock price more than […]