Deborah George

Deborah George

Deborah George is a member of Robinson+Cole’s Business Litigation Group as well as its Data Privacy + Cybersecurity Team. Ms. George advises clients on and focuses her practice on data privacy and security, cybersecurity, and compliance with related state and federal laws. She also has experience providing counsel in civil litigation and employment law matters. She has significant experience offering advice and counsel on legal issues related to human services agencies, including Medicaid, as well as drafting and reviewing contracts, business associate agreements, and data use agreements. Read her full rc.com bio here.

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Is Your Business Collecting COVID-19-Related Employee Data? If So, You May Need to Update Your CCPA Employee Notice

The California Consumer Privacy Act (CCPA) requires businesses covered by the CCPA to notify their employees of the categories of personal information the business collects about employees and the purposes for which the categories of personal information are used. The categories of personal information are broadly defined in the CCPA and include personal information such … Continue Reading

California’s Consumer Privacy Rights Act (CPRA): Key Effective Dates and the Creation of the California Privacy Protection Agency

With the passage of the ballot initiative known as the Consumer Privacy Rights Act (CPRA or Act) in California, we are presenting several blog articles on different topics related to this new law. Last week, we wrote about the newly-added definition of sensitive information. This week we will focus on some key effective dates in … Continue Reading

Sensitive Personal Information – What Is It and What Does It Mean for California Privacy Rights Act Compliance?

The California Privacy Rights Act (CPRA) expands the definition of personal information as it currently exists in the California Consumer Privacy Act (CCPA). The CPRA adds “sensitive personal information” as a defined term, which means: (l) personal information that reveals: (A) a consumer’s social security, driver’s license, state identification card, or passport number; (B) a … Continue Reading

California’s Proposition 24 – CCPA 2.0 Meets the California GDPR

Proposition 24 is known as the California Privacy Rights Act of 2020 (CPRA). It is on the ballot in California on November 3, and if it passes it will amend and expand certain provisions of the California Consumer Privacy Act (CCPA). Some say it’s CCPA 2.0, however, there are some provisions that make the CPRA … Continue Reading

CCPA Amendments Signed by Governor Newsom

Recently we wrote about two amendments to the California Consumer Privacy Act of 2018 (CCPA) that were awaiting signature on Governor Newsom’s desk: AB 1281, which extends the one-year exemptions for employee information and business to business information for another year until January 1, 2022; and AB 713, which provides an exemption from the CCPA … Continue Reading

California Bill Extends CCPA Exemptions for Personal Information Collected by Employers and Businesses

The California Consumer Privacy Act of 2018 (CCPA) currently exempts from its provisions certain information collected by a business about a natural person in the course of the person acting as a job applicant, employee, owner, director, officer, medical staff member, or contractor of a business. This exemption is set to expire on December 31, … Continue Reading

CCPA Final Proposed Regulations Filed

The California Attorney General submitted the final proposed California Consumer Privacy Act (CCPA) regulations on June 1, 2020 to the California Office of Administrative Law (OAL) for review. According to the Attorney General’s submission, OAL has thirty working days to review the regulations, plus an additional sixty calendar days under the Governor’s Executive Order N-40-20 … Continue Reading

CCPA 2.0 May Be Heading for the November Ballot in California

The consumer group Californians for Consumer Privacy announced on May 4, 2020, that it was submitting well over 900,000 signatures to qualify the California Privacy Rights Act (CPRA) for the November 2020 ballot. This new ballot initiative, which can be reviewed here, creates some additional consumer privacy rights and expands some areas already included in … Continue Reading

New York Department of Financial Services Issues Guidance Regarding Heightened Cybersecurity Awareness During COVID-19 Pandemic

The New York Department of Financial Services (DFS) recently issued guidance to its regulated entities regarding heightened cybersecurity awareness as a result of the COVID-19 pandemic. DFS described three primary areas of heightened risk during this time: remote working, increased instances of phishing and fraud, and third-party risks. With respect to remote working, DFS noted … Continue Reading

Businesses and Trade Groups Seek Delay in CCPA Enforcement Actions

Recently businesses and advertising trade groups wrote a letter to the California Attorney General Xavier Becerra to request delayed enforcement of the California Consumer Privacy Act (CCPA) as a result of the COVID-19 global pandemic. The letter cited the current health crisis as a result of COVID-19 and a state of national emergency as the … Continue Reading

California Attorney General Releases Additional Modifications to Draft CCPA Regulations

On March 11, 2020, the California Attorney General released the second set of modifications to the draft California Consumer Privacy Act (CCPA) regulations. This set of modifications contains deletions to language that was included in the February modifications to the regulations as well as some new language. Notable changes include the deletions of the “do … Continue Reading

Department of Health & Human Services Office for Civil Rights Issues Guidance Regarding HIPAA Privacy and Novel Coronavirus

The Office of Civil Rights (OCR) last month provided guidance and a reminder to HIPAA covered entities and their business associates regarding the sharing of patient health information (PHI) under the Health Insurance Portability and Accountability Act (HIPAA) Privacy Rule during an outbreak or emergency situation such as what we are all facing right now … Continue Reading

OIG Audit Finds that Majority of Part D Providers Surveyed Used E1 Transactions for Potentially Inappropriate Purposes

The Centers for Medicare and Medicaid Services (CMS) requested an audit by the Office of Inspector General (OIG) of Medicare Part D eligibility verification transactions (E1) transactions. The OIG recently released its report which found that the majority of the providers evaluated used E1 transactions for some inappropriate purpose other than to bill for a … Continue Reading

The Washington Privacy Act – Re-Introduced for 2020 – Is it the Best of CCPA and GDPR?

Washington legislators recently introduced the Washington Privacy Act (WPA). This legislation is a consumer-focused privacy law similar to the California Consumer Privacy Act (CCPA) but it also has some European Union General Data Protection Regulation (GDPR)-like concepts. The WPA protects personal data in much the same way as the CCPA, but with some significant differences. … Continue Reading

California Attorney General Releases Modified Draft CCPA Regulations

On February 10, 2020, the California Attorney General’s Office released modified California Consumer Privacy Act (CCPA) regulations. There are some notable differences in the regulations from the first draft, which can be seen in this redlined version. This article will highlight some of the new language added in the latest draft of the regulations. What’s … Continue Reading

IoT Manufacturers – What You Need to Know About California’s IoT Law

California has a privacy law that took effect on January 1, 2020, and it’s not the California Consumer Privacy Act (CCPA). This new privacy law regulates Internet of Things (IoT)-connected devices. SB 327 was enacted in 2018 and became effective on January 1, 2020. The California IoT law requires manufacturers of connected devices to equip … Continue Reading

NIST Releases Privacy Framework: A Tool for Improving Privacy Through Enterprise Risk Management

The National Institute of Standards and Technology (NIST) released its first privacy framework tool  (the Privacy Framework) on January 16, 2020. In the Executive Summary, NIST states that with the unprecedented flow of data of individuals through a complex digital ecosystem, individuals may not be able to understand the potential consequences for their privacy as they … Continue Reading

Knowledge is Power: California Attorney General Issues Advisory on the CCPA

California Attorney General Xavier Becerra said last week that “knowledge is power, and in today’s world knowledge is derived from data. When it comes to your own data, you should be in control…” These words came in an Advisory highlighting California consumers’ rights under the California Consumer Privacy Act (CCPA). The Advisory outlined several areas … Continue Reading

CCPA Recap for the New Year

After much anticipation and trepidation, the California Consumer Privacy Act (CCPA) went into effect on January 1, 2020. Many companies are understandably still grappling with the details of the law, the amendments, and the proposed regulations and how to comply with them. If you have not determined whether the CCPA applies to your company, and … Continue Reading

FTC Settles First Case Involving Stalkerware

Would you hand over your smartphone, including your call history, text messages, photos, GPS locations, and browser history to your employer? To your significant other? How about to a random stranger? I’m guessing your answer is an overwhelming “No” to each of these questions. Stalkerware and stalking apps do just that. Both are spyware that … Continue Reading
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