The Privacy Law Network editorial team tracks privacy and data protection developments across US federal and state law. We report from primary sources: statutes and bill text, agency press releases and guidance, regulator enforcement orders, and court filings and opinions. Every article links the underlying documents so readers can verify what we report rather than take our word for it. We are not attorneys and we do not provide legal advice. Our coverage describes what laws and regulators say; it does not assess how any of it applies to a particular person or business. For that, consult a licensed attorney.

Recent Coverage

Canada (PIPEDA)

Alberta and British Columbia Each Have a Personal Information Protection Act. They Are Not the Same Law

September 21, 2026

Two federal exemption orders registered on the same day in 2004 let Alberta's and British Columbia's private-sector privacy statutes displace PIPEDA inside each province. The Acts share a name and identical fine ceilings, but only Alberta's requires breach reporting, they define employee information and treat non-profits differently, and BC has credit-reporting amendments due in 2027.

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Brazil (LGPD)

Brazil's Encarregado Regulation: The Appointment Paperwork, the Website Notice and the Conflict Rules

September 21, 2026

The LGPD says a controller must appoint an encarregado and publish how to reach them, and leaves the rest to the regulator. Resolution CD/ANPD No. 18 of 16 July 2024 supplies it: a written, dated and signed act of appointment, a named substitute, a minimum content for the public notice, five duties the organisation owes its encarregado, and a conflict-of-interest regime that can lead to sanctions.

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China (PIPL)

China's Network Data Regulations Put a Price on Scraping, Recommendation Switches and Important Data

September 21, 2026

The Regulations on Network Data Security Management are an administrative regulation of the State Council, made to implement three statutes at once rather than one. They define who a network data processor is, add concrete rules on privacy notices, portability and personalised recommendation, impose annual risk reporting on holders of important data, and set their own fine schedule.

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China (PIPL)

China's PIPL Audit Duty Waited Four Years for a Frequency, a Trigger List and an Annex of 27 Checks

September 21, 2026

Article 54 of China's Personal Information Protection Law has required regular compliance audits since November 2021, without saying how often, by whom or against what. The CAC's Measures for Personal Information Protection Compliance Audits, in force since 1 May 2025, supply those answers, and add a second route by which a regulator can order an outside audit at the processor's expense.

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State Comprehensive Privacy Laws

Public Act 25-113 Rewrote the Connecticut Data Privacy Act on July 1, 2026, and a 2026 Act Rewrites Part of It Again in October

September 21, 2026

Substitute Senate Bill 1295 became Public Act 25-113 on June 24, 2025. Its Data Privacy Act sections took effect together on July 1, 2026: a lower threshold, two no-threshold triggers, more sensitive data, profiling rights, impact assessments and a ban on selling teenagers' data. Public Act 26-64 amends several of the same sections again from October 1, 2026.

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Cross-Border Transfers

The Justice Department's Bulk Sensitive Data Rule: Six Countries, Six Data Categories, and Two Compliance Dates in 2025

September 21, 2026

Executive Order 14117 directed the Attorney General to bar or condition transactions that give six foreign governments, and persons tied to them, access to Americans' bulk sensitive data. The resulting rule, 28 CFR part 202, took effect April 8, 2025. Its due diligence, audit and reporting duties followed on October 6, 2025. The only change to the text since publication is a one-line correction.

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Data Security Rules

Five Years of the Civil Cyber-Fraud Initiative: Sixteen Settlements, Ten Whistleblower Suits and No Judgment

September 21, 2026

The Justice Department launched the Civil Cyber-Fraud Initiative on October 6, 2021 to pursue government contractors and grantees under the False Claims Act for knowing cybersecurity failures. This publication located sixteen resolved matters announced in DOJ releases through September 1, 2026, totaling about $69.1 million. Every one settled, and most began as whistleblower suits.

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India (DPDP Act)

The Data Protection Board of India Exists in Law, Has a Pay Scale and a Selection Committee, and Has No Members Yet

September 21, 2026

The Data Protection Board of India was established by Gazette notification on 13 November 2025, with its head office in the National Capital Region. MeitY invited applications for a Chairperson and four Members in May 2026, and no appointment had been notified by 21 September 2026. This explainer covers its staffing, its digital procedure and which of its powers are not yet in force.

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India (DPDP Act)

India's DPDP Breach Rule Has No Harm Threshold and a 72-Hour Report, and It Does Not Start Until 2027

September 21, 2026

Section 8(6) of India's Digital Personal Data Protection Act requires a Data Fiduciary to tell the Data Protection Board and each affected individual about a personal data breach, and rule 7 of the 2025 Rules fills in the content and a 72-hour clock. Both sit in the commencement tranche that starts eighteen months after 13 November 2025, while CERT-In's six-hour incident reporting already applies.

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Brazil (LGPD)

The LGPD's Small-Business Regime: Who Qualifies, Who Is Excluded and Which Clocks Run at Double Speed

September 21, 2026

Resolution CD/ANPD No. 2 of 2022 gives micro and small enterprises, startups, non-profits and individuals acting as controllers or processors a lighter version of the LGPD: a simplified record of processing, no mandatory encarregado, and doubled deadlines. Three exclusions take it away, the ANPD can withdraw it case by case, and a 2024 regulation rewrote one deadline rule.

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State Comprehensive Privacy Laws

New York's Child Data Protection Act: Nine Sections, a Consent Form With Four Conditions, and Rules Still Unproposed

September 21, 2026

Chapter 121 of the Laws of 2024 added article 39-FF, sections 899-ee to 899-mm, to New York's General Business Law. It has applied since June 20, 2025 to operators whose users are known minors or whose services are primarily directed to minors. The Attorney General issued an advance notice in 2024 and implementation guidance in May 2025, but has not published proposed rules.

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Canada (PIPEDA)

Canada's Meaningful Consent Guidelines Sort Themselves Into Must and Should. Here Is Which Is Which

September 21, 2026

The Guidelines for obtaining meaningful consent were issued jointly by the federal Privacy Commissioner and the Alberta and British Columbia commissioners in May 2018 and last modified in August 2025. They set seven principles, four elements that must be emphasised, three triggers for express consent and an under-13 position on children, and label each item an obligation or a best practice.

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GLBA

The CFPB's Personal Financial Data Rights Rule: The Text of Part 1033 and the Injunction That Froze It

September 14, 2026

The Personal Financial Data Rights Rule, 12 CFR part 1033, requires banks, card issuers and other data providers to make consumer financial data available to consumers and authorized third parties. The rule remains on the books, but since October 29, 2025 the CFPB has been enjoined from enforcing it while it reconsiders the rule, and appeals from that order are paused.

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Dark Patterns

The FTC Negative Option Rule After Click-to-Cancel: What Was Vacated and What Part 425 Says Now

September 14, 2026

Between late 2024 and early 2026, 16 CFR Part 425 said three different things. The FTC's click-to-cancel amendments took effect, were vacated by the Eighth Circuit on procedural grounds weeks before full compliance was due, and were replaced by the 1973 book-club rule. This sets out what each version says, why the court ruled as it did, and what federal law governs online subscriptions today.

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UK Data Protection

How the ICO Calculates a UK GDPR Fine: The Five Steps in Its Data Protection Fining Guidance

September 14, 2026

The Information Commissioner's Office published its Data Protection Fining Guidance on 18 March 2024 under section 160 of the Data Protection Act 2018. It explains when the regulator issues a penalty notice and how it reaches an amount, from a seriousness band through a turnover adjustment to a final check against the statutory cap. Both are set out here.

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Data Security Rules

The NAIC Insurance Data Security Model Law: What Model #668 Requires and How Eight States Rewrote It

September 14, 2026

The NAIC adopted its Insurance Data Security Model Law in late 2017 as a template for state legislatures. It asks insurance licensees to run a written information security program, oversee vendors, investigate cybersecurity events and notify the insurance commissioner within 72 hours. This walks through the model's text and compares it with eight enacted state versions.

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State Comprehensive Privacy Laws

The Maryland Online Data Privacy Act as Enacted: New Section Numbers, No Consent Route and a 2026 Rewrite

September 14, 2026

The Maryland Online Data Privacy Act has applied since October 1, 2025, but not at the section numbers its bill record gives, or in the form its chapter law's plain text suggests. This post sets out the statute as the General Assembly now publishes it, the Attorney General's reading of its minimization rule, and the immigration-enforcement amendments effective July 1, 2026.

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Data Security Rules

New York's SHIELD Act: The Section 899-bb Security Requirement and the Breach Law Changes Since 2019

September 14, 2026

The SHIELD Act of 2019 did two things: it widened New York's breach notification statute, General Business Law section 899-aa, and it added section 899-bb, a standalone duty to maintain reasonable data security. This sets out the security requirement as enacted, the routes to deemed compliance, and the three later chapters that changed section 899-aa without touching section 899-bb.

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Ransomware

When Ransomware Encrypts Health Data, HIPAA Presumes a Breach: How the Presumption Works

September 14, 2026

HHS does not treat ransomware as a mere outage outside the breach rules. Its Office for Civil Rights reads encryption by an attacker as an acquisition of the data, which brings the incident within the regulatory presumption of breach at 45 CFR 164.402. This sets out where that presumption came from, what rebutting it involves, and the clocks that follow when it stands.

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State Comprehensive Privacy Laws

Vermont's Age-Appropriate Design Code: What Act 63 Requires of Online Services From January 1, 2027

September 14, 2026

Vermont enacted its Age-Appropriate Design Code as Act 63 of 2025, signed June 12, 2025. The substantive duties begin on January 1, 2027, but the Attorney General's rulemaking powers took effect in July 2025 and proposed rules are open for comment until October 2, 2026. This post covers its definitions and duties and compares them with the California provisions the Ninth Circuit has ruled on.

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