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Robert Bateman is a data protection writer, trainer, and consultant. He has published innumerable articles on the topic, as well as led panel discussions and interviewed key well-known figures in the space on stage, at well-known privacy conferences. Besides freelancing as content creator, he is an associate with Act Now Training and a Subject Matter Expert with Heward Mills, a data protection consultancy.
With Robert, who’s here for a second time, we are going to revisit recent EDPB (or European Data Protection Board) opinions on data processor auditing requirements and Meta’s Consent or Pay model, with its latest twist in mind (a brand new third option with generic, unskippable ads).
References:
Robert Bateman on LinkedIn EDPB Opinion 22/2024 on certain obligations following from the reliance on processors and sub-processors Meta adds a Plan C to its Pay or Consent model EDPB Guidelines on the technical scope of article 5.3 of the ePrivacy Directive Robert Bateman: Consent or Pay (Masters of Privacy, October 2023) -
Time for a Newsroom summarizing everything that’s happened in our usual areas of focus, although we are dropping the last two (Zero-Party Data and Future of media) this time around.
ePrivacy & Regulatory Updates EnforcementOn September 5th, the CNIL fined CEGEDIM SANTÉ 800,000 euros for processing health data without authorization. The healthcare software provider collected sensitive personal information, assigning a unique identifier for each patient of the same doctor. This method was considered sufficient to ensure that personal data remained anonymous in order to put together certain comparative studies, but the CNIL concluded that, given the risk of re-identification, it could merely be considered pseudonymized, exposing a breach of the GDPR as a result (for starters, patients had not been informed of additional purposes). A Reference was made to the EDPB’s Opinion 05/2014 on Anonymisation Techniques.
On September 27th The Irish DPC issued a 91 million euro fine to Meta for storing certain user passwords in plain text files.
On October 22nd, NOYB filed a claim against Pinterest before the French supervisory authority alleging that the company relies on legitimate interest to underpin its behavioral advertising practices, in contravention of the CJEU Bundeskartellamt decision. The social network has also been accused of breaching the transparency principle and not responding to data subject requests appropriately.
On October 24th, the Irish DPC imposed a 310m EUR fine on LinkedIn. The professional social network is not properly applying a valid legal basis for targeted ads and the processing of first party data about their members, despite referring to three separate grounds: consent, legitimate interest and contractual necessity. This has also resulted in a breach of the fairness principle.
On October 30th, the California Privacy Protection Agency announced an investigative sweep of data broker registration compliance under the Delete Act. This law requires data brokers to register with the CPPA and pay a fee annually.
On November 6th, the Canadian government ordered the closure of TikTok in the country. Citizens are however allowed to keep using the app, as this is considered a personal choice.
Legal updates and guidelinesOn October 4th, the CJEU resolved a famous dispute between the Royal Dutch Lawn Tennis Association and the Dutch DPA. The latter had imposed a fine on KNLTB for relying on legitimate interest for sharing data with its sponsors for purposes of direct marketing.
Five days later, the EDPB requested comments on its draft Opinion on processing data on the basis of Legitimate Interest: It is made clear that this legal basis should not be treated as a “last resort” as it is of equal value to the rest, and a differentiation is made between an interest (or broader benefit that a controller may have) and a purpose (or specific reason why the data is processed). The Opinion has also stated that an interest must be related to the data controller’s activities.
On the same day (October 9th), the EDPB adopted its Opinion 22/2024 on certain obligations following from the reliance on processors and sub-processors: every controller should extend the diligence they currently have over direct processors to the entire chain of custody, no matter how many degrees apart.
On October 16th, the EDPB adopted new Guidelines on the technical scope of article 5.3 of the ePrivacy Directive: given that very little has changed since they opened up an initial draft for comments, we recorded a separate episode with Peter Craddock pondering the far reaching implications of these Guidelines.
Turning our attention to the UK, on October 7th the UK ICO launched its own Data Protection Audit Framework including self-assessment toolkits and other practical resources.
Also, the UK Data Protection reform is back, now with a Data Use and Access Bill (with a second reading announced on November 1st). It maintains an exception for analytics cookies that will not require consent. DPOs are back on the table (the previous reform proposal was getting rid of the role).
On November 5th EDPB adopted its first report under the EU-U.S. Data Privacy Framework and a statement on the recommendations on access to data for law enforcement. The redress mechanism has been implemented successfully but it is yet not being widely used. The EDPB has voiced concerns about recent changes to Section 702 FISA and how that could expand the role of private companies in gathering data about EU citizens.
MarTech and AdTechOn November 12th, Meta introduced a plan C to its Pay or Consent models, having been told by the EDPB that the current proposal would not be acceptable. A third option (besides paying and relying on behavioral ads) is now available which will use less data and remain mostly contextual. It will also compensate its decreased targeting capabilities with increased audience reach by showing ads (“ad breaks”) that become unskippable for a few seconds.
A study conducted by Boston University has concluded that the Protected Audiences API (building on the formerly called FLEDGE protocol, a part of Chrome’s Privacy Sandbox), can produce similar results to those of third party cookies in the context of retargeting campaigns.
On November 5th, David Raab, who back in the day had coined the label CDP (Customer Data Platform), published a provocative piece titled “The Composable CDP is Dead”. In summary the author argues that all CDPs have already caught up with the modularization that came from sitting on top of more flexible data warehouses, so every single CDP has either become a niche modular component or an all-encompassing, highly-modularized software suite. In sum, the term will not help a Hightouch differentiate itself uniquely any longer. We suggest that you listen to our interviews with Tejas Manohar and Jonathan Mendez, CEOs of Hightouch and Neuralift AI respectively, for further context.
AI, Competition and Digital MarketsThe community is still recovering from Hamburg’s DPA’s opinion (adopted on July 15th) stating that LLMs do not contain personal data. The supervisory authority made three key points that we will be covering with some future guests: a) No personal data is stored in LLMs; b) Data subject rights as defined in the GDPR cannot relate to the model itself, but they can be exercised against the provider or deployer of a system built on top of such models, with regards to the input or output of such system; c) The training of LLMs using personal data must comply with data protection regulations.
The Irish DPC announced an investigation into Google’s foundational AI model (PaLM 2) on September 12th, with a focus on the DPIA that Google is expected to have undertaken.
An ICO report released on November 8th found that AI recruitment technologies can filter candidates according to protected characteristics including race, gender, and sexual orientation.
On November 13th, Meta received an 800,000 EUR fine for anti-competitive practices in the bundling of its Marketplace feature with the primary Facebook application. So, they have leveraged their control over one market to take control of another, adjacent market, in this case threatening pretty large companies in the classified ads space.
That’s it for today! Thanks again for listening.
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The EDPB has finally adopted its much feared Guidelines on the scope of article 5.3 of the ePrivacy Directive, but consent may still be avoided in some cases not specifically covered by an exemption (e.g., analytics). Absent such an exception, and in light of dismal consent rates, publishers and platforms have embraced highly controversial “Consent or Pay” models. Plan C? Server-side processing (Conversion APIs, Enhanced Conversions, Data Clean Rooms…), not without its own challenges.
We have gone through all of it with Peter Craddock in his second appearance on Masters of Privacy.
Peter Craddock is a lawyer as well as a software developer, and he uses this dual background to help clients find legal solutions to technical problems and technical solutions to legal problems. He is based in Brussels and helps international companies with their global data strategy and with EU data litigation. He notably has strong expertise in the legal aspects of digital advertising and adtech, and has been one of the most prominent commentators of recent legal developments in that area.
References:
Peter Craddock on LinkedIn Op-Ed: A critical analysis of the EDPB's "Pay or Consent" Opinion (Peter Craddock) Peter Craddock: Comparison of the final version of the EDPB’s ePrivacy guidelines with the version of November 2023 (including links to more in-depth comments on those guidelines) EDPB Opinion 08/2024 on Valid Consent in the Context of Consent or Pay Models Implemented by Large Online Platforms AEPD guidelines for the use of cookies without need for consent in the context of digital analytics (ES) Peter Craddock on Masters of Privacy (February 2024): Could core advertising components fall under the “strictly necessary” exemption of the ePrivacy Directive? Romain Robert: Pay or OK in AdTech - How it started and where it’s going (Masters of Privacy) Renzo Marchini: Unintended consequences of the EDPB guidelines on storage and access under article 5.3 of the ePrivacy Directive (Masters of Privacy) Cristiana Santos and Victor Morel: The problem with CMPs and TCF-based cookie paywalls (Masters of Privacy) Robert Bateman: Consent or Pay (Masters of Privacy) Peter Hense: How first party data will kill CMPs (Masters of Privacy) -
Dr Lukasz Olejnik (@lukOlejnik), LL.M, is an independent cybersecurity, privacy and data protection researcher and consultant. Senior Visiting Research Fellow of the Department of War Studies, King’s College London. He holds a Computer Science PhD at INRIA (French Institute for Research in Digital Science and Technology), and LL.M. from University of Edinburgh. He worked at CERN (European Organisation for Nuclear Research), and was a research associate at University College London. He was associated with Princeton's Center for Information Technology Policy, and Oxford's Centre for Technology and Global Affairs. He was a member of the W3C Technical Architecture Group. Former cyberwarfare advisor at the International Committee of the Red Cross in Geneva, where he worked on the humanitarian consequences of cyber operations. Author of scientific articles, op-eds, analyses, and books Philosophy of Cybersecurity, and “Propaganda”. He contributes public commentary to international media.
References:
Full interview transcript (on Medium) Propaganda, by Lukasz Olejnik Lukasz Olejnik on Cyber, Privacy and Tech Policy Critique (Newsletter) Lukasz Olejnik on Mastodon Lukasz Olejnik on X EU Digital Services Act (DSA) Section 230 (“Protection for private blocking and screening of offensive material“) of the Communications Decency Act (1996) Cubby, Inc. v. CompuServe Inc. and Stratton Oakmont, Inc. v. Prodigy Services Co. as precursors to Section 230 Doppelganger in action: Sanctions for Russian disinformation linked to Kate rumours EU takes shot at Musk over Trump interview — and EU takes shot at Musk over Trump interview — and misses (Politico) The story of Pavel Rubtsov (“Journalist or Russian spy? The strange case of Pablo González”), The Guardian Silicon Valley, The New Lobbying Monster (mentioning Chris Lehane’s campaigns), The New Yorker Financial Times: Clip purporting to show a Haitian voting in Georgia is among ‘Moscow’s broader efforts’ to sway the race “Pseudo-media”: Spain proposes tightening rules on media to tackle fake news -
Can we leverage AI-generated synthetic data as a privacy-enhancing or data anonymization solution? How compatible is it with Data Clean Rooms? Will there be a path to effectively anonymize unstructured data?
Ben Winokur is the co-founder and CEO of Subsalt, the leading platform for anonymous synthetic data. Prior to Subsalt, Ben worked in a variety of legal, product, and operational roles at Passport, where he first encountered the problem Subsalt solves: privacy and security risks have made it too expensive and difficult to access, share, and analyze sensitive private data.
References:
Ben Winour on LinkedIn Subsalt Jonathan Mendez and Alex Dean: Data Clean Rooms: Feature, Product or Platform? European Data Protection Supervisor: TechSonar report on Synthetic Data (and its use as a Privacy Enhancing Technology) -
Monica Meiterman-Rodriguez is a Partner at Tueoris, an international privacy and security consulting firm, currently residing in Barcelona. She utilizes her US law degree and her experience in data protection and privacy to assist global clients in developing, maintaining, or growing their privacy programs. She has experience supporting compliance across global regulations including US state and federal requirements, EU/UK GDPR, PIPEDA, LGPD, etc. in addition to advising on specialized matters in the AdTech space such as targeted advertising, data analytics, AI and growing industry guidance (e.g., IAB, DAA, etc.).
Monica is a member of the New York State Bar, New Jersey State Bar, as well as a Certified Information Privacy Professional (CIPP/US/E) and the Chapter Chair of the IAPP in Barcelona (Spain).
References:
Monica Meiterman on LinkedIn California Consumer Privacy Act EDPB Guidelines 01/2022 on data subject rights - Right of access GDPR Violation: German Privacy Regulator Fines 1&1 Telecom(BankInfoSecurity) Groupon Ireland Operations Limited – March 2024: the DPC finds that Groupon infringed Article 5(1)(c) GDPR by having initially required the complainant to provide a copy of their ID in order to verify their identity for the purposes of their access and erasure requests. -
Simon Hania is Global Data Protection Officer at Uber, heading the team that independently advises on and monitors Ubers compliance with data protection laws. In the past Simon held the position of VP Privacy & Security at TomTom and before that various positions in IT service management. Simon is a trained engineer who has learned to love the law.
References:
Simon Hania on LinkedIn Masters of Privacy Summer Newsroom, covering Uber’s $290 EUR fine in The Netherlands Glovo (food delivery) receives a 500k EUR AEPD fine for sending rider location data across borders (started in Italy) FTC Finalizes Order with X-Mode and Successor Outlogic Prohibiting it from Sharing or Selling Sensitive Location Data Uber Ads -
The IAPP’s annual “Privacy. Security. Risk.” event took place in Los Angeles last week. Both Celine Takatsuno and Sergio Maldonado attended, took some notes, and now share their experiences and takeaways.
References:
Sergio Maldonado (Medium): PSR 2024 Takeaway (DPAs, Vendor Audits, MHMD Act) Mike Hintze: Blog post series on Washington State’s My Health My Data Act IAPP: Agenda and speakers at PSR 2024. -
Jonathan Mendez has been a founder and leader in Adtech and Martech for two decades, with a focus on building first-party data products to optimize media performance.
He is the founder and CEO at Neuralift AI, having prior to that been Chief Digital Officer at a major cruise line, and having also spent five years building composable CDPs (Customer Data Platform) for global retail brands and telcos. He was also the Founder and CEO of Yieldbot, which in 2016 was the fourth largest Digital Advertising Network. He was also the CSO at Offermatica, eventually acquired by Omniture, now part of Adobe.
Jonathan’s blog has been active for 17 years and is a recognized source of insights into AdTech, MarTech or Media.
References:
Jonathan Mendez (blog): Optimize & Prophesize Neuralift AI Jonathan Mendez on X Jonathan Mendez on LinkedIn Tejas Manohar (Hightouch): data activation and composable CDPs in a privacy-first world (Masters of Privacy) Nicola Newitt (Infosum): the legal case for Data Clean Rooms (Masters of Privacy) Matthias Eigenmann (Decentriq): Confidential Computing, contractual relationships and legal bases for Data Clean Rooms (Masters of Privacy) -
What extra steps should data processors and controllers worry about now that every cloud-based tool is somehow AI-powered?
A basic transparency principle is common across FIPPs, governance frameworks and existing AI regulations (EU, Colorado), but even that can sometimes become a luxury.
Attorney Heidi Saas (CIPP/US) has over eighteen years of experience in consumer rights, six years in data privacy, and three years of ethical AI and governance experience. Her projects currently involve working with CEOs, CTOs, CISOs, DPOs, and CMOs of companies in various industries on regulatory strategy, privacy program designs, risk management, implementation, and monetization of data assets within their privacy ecosystems. She also works with businesses to provide ethical AI advisory, and pre-audit consulting services, as well as regulatory compliance, legal consulting, and public speaking events.
References:
Heidi Saas on LinkedIn Colorado AI Bill (Consumer Protections in Interactions with Artificial Intelligence) Fair Information Practice Principles (FIPPs) Twilio Under Investigation for Data Breach of Over 33 Million Authy MFA Users Medicaid for millions in U.S. hinges on Deloitte systems plagued by errors -
This is our second interview analyzing the impact of Google’s decision not to deprecate third-party cookies on its Chrome browser.
Daniel Jaye is a seasoned technology industry executive and currently is CEO and founder of Aqfer, a Marketing Data Platform on top of which businesses can build their own MarTech and AdTech solutions.
Daniel has provided strategic, tactical and technology advisory services to a wide range of marketing technology and big data companies. Clients have included Brave Browser, Altiscale, ShareThis, Ghostery, OwnerIQ, Netezza, Akamai, and Tremor Media. He was the founder and CEO of Korrelate, a leading automotive marketing attribution company -purchased by J.D. Power in 2014- as well as the former president of TACODA -bought by AOL in 2007. Daniel was also the founder and CTO of Permissus, an enterprise privacy compliance technology provider.
All of the above were preceded by his role as founder and CTO of Engage, acting CTO of CMGI and director of High Performance Computing at Fidelity Investments. He also worked at Epsilon and Accenture (formerly Andersen Consulting).
Daniel Jaye graduated magna cum laude with a BA in Astronomy and Astrophysics and Physics from Harvard University.
References:
Daniel Jaye on LinkedIn Aqfer P3P: Platform for Privacy Preferences (W3C) Luke Mulks (Brave Browser) on Masters of Privacy Adnostic: Privacy Preserving Targeted Advertising (paper by Vincent Toubiana, Arvind Narayanan, Dan Boneh, Helen Nissenbaum, Solon Barocas) -
Earlier this summer, Google announced that its Chrome browser would after all keep third party cookies. This interview with Robin de Wouters is the first of two episodes exploring the consequences of that update from the point of view of our usual stakeholders (DPOs, CMOs, CDOs).
Robin de Wouters is the Director General for the Federation of European Data & Marketing (FEDMA), in Brussels. He has a strong background in communication and public relations across the private, non-profit and institutional spheres. He previously worked in the field of human rights with Euromed Rights, the ONE Campaign and the United Nations. Robin is also the Vice-Chair of the Board of the European Interactive Digital Advertising Alliance (EDAA) and the Communications Director and Spokesperson for Democrats Abroad Belgium, the international arm of the US Democratic Party.
References:
Federation of European Data and Marketing (FEDMA) Robin de Wouters on LinkedIn Sergio Maldonado, Nobody was ready for the Privacy Sandbox, but deprecating cookie banners is long overdue Google announces they are not deprecating third-party cookies Peter Cradock (Masters of Privacy): Could core advertising components fall under the “strictly necessary” ePrivacy exemption? CNIL publishes study on alternatives to third-party advertising cookies (Freevacy) -
Ok, the summer is nearly over, which means it is time for a Newsroom summarizing everything that’s happened in the last two months at the intersection of marketing, data, privacy and technology.
California and the FTC have more specific weight on our list this time around - perhaps because much of Europe, including regulators and hackers, was OOO during the entire month of August. So, expect to hear about:
A CDP (Segment) being sued for its data collection practices Uber’s Catch-22 The FTC discards hashing as a means of anonymization Chrome could be forced to support Global Privacy Control The AI Bill drama in California.(And yes, also about Google’s monopoly, the resilience of 3rd party cookies and Apple’s DMA struggles, but only in passing, as you’ve probably had enough of those.)
Expect us to follow the usual structure: ePrivacy & Regulatory Updates; MarTech & AdTech; AI, Competition and Digital Markets; Zero-Party Data and Customer Centricity; Future of Media.
With Celine Takatsuno and Sergio Maldonado.
References:
Sergio Maldonado, Nobody was ready for the Privacy Sandbox, but deprecating cookie banners is long overdue (ie., third party cookies are not going away) Class action was filed against Twilio in California Uber received a $290m euro fine in The Netherlands The Federal Trade Commission audited hundreds of websites and apps, finding all sorts of dark patterns Controversial California AI Bill California passes another law that, if signed, will require browsers to implement Global Privacy Control standards FTC: Hashing email addresses does not result in anonymized data Netflix announces data collaboration partnerships Apple tries a little harder to appease the EU Commission with additional Digital Markets Act measuresAlso, find a full blog post on the Masters of Privacy website.
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Jay Averitt is currently a Senior Privacy Product Manager at Microsoft, where he manages technical privacy reviews involving Microsoft365 products including CoPilot, GPT, and other LLM products. He was previously a Privacy Engineer at Twitter, where he managed technical privacy reviews across the platform. He’s been working in privacy for over a decade as both a privacy technologist and a privacy attorney. Before switching to technical privacy, he worked as a technology counsel at SAP, SAS, and Lenovo.
References:
Jay Averitt on LinkedIn NIST, Privacy Engineering Program Daniel J. Solove, Against Privacy Essentialism María P. Angel and Ryan Calo, Distinguishing Privacy Law: A Critique of Privacy as Social Taxonomy Sergio Maldonado, Some takeaways from PEPR’24 (USENIX Conference on Privacy Engineering Practice and Respect 2024) -
Nick Manning is a commentator, author and speaker on advertising, with a specialization in media. He co-founded Manning Gottlieb Media in 1990, and following its purchase by Omnicom he became CEO of the OMD UK Group. He also co-founded OPera, the media negotiation arm for OMD and PHD. In 2007 Nick joined Ebiquity as Chief Operating Officer before becoming responsible for Ebiquity’s non-UK based operations and Chief Strategy Officer. At Ebiquity he led the team that produced the recommendations for advertisers that accompanied the K2 Intelligence report into media transparency in 2016.
Since 2019 he has run his own consulting business, advising advertisers and their trade associations. Nick specializes in helping advertisers improve their effectiveness, accountability and transparency.
References:
Advertising, Who Cares? A Summit event happening at London’s Royal Society of Arts on September 12th 2024, aiming to discuss possible solutions around five topics: Business models; Trading, Transparency and Trust; Measurement and Accountability; Recruitment and Well-Being; Brands and Journalism. Nick Manning’s Encyclomedia, “fractional” Chief Media Officer services. Nick Manning on X Nick Manning on LinkedIn Arielle Garcia on Masters of Privacy Sergio Maldonado, How we tried to fix advertising, ecommerce, and media by putting people in control of their data Augustine Fou on Masters of Privacy -
Tony Fish is an investor, author and self-confessed maverick. He has been building digital businesses since 1990, with a first exit in 1995 and many businesses founded, co-founded, sold and listed after that. He thrives in complex, groundbreaking and uncertain environments, being currently focused on rethinking corporate governance models, ethics and AI, data policy and evidence-based decision making in volatile situations. He is a speaker and author of four books, as well as a visiting fellow for entrepreneurship and innovation at Henley Business School, has taught at London Business School in AI and Ethics, the London School of Economics and Sydney Business School. His latest book (“Decision-making in uncertain times”) has been widely available since early June.
References:
Tony Fish, Decision-making in uncertain times Tony Fish, Why is data eating your culture before breakfast My Digital Footprint, a blog by Tony Fish Open Governance (Tony Fish on Medium) Tony Fish on LinkedIn Distinguishing Privacy Law: A Critique of Privacy as Social Taxonomy (María P. Angel, Ryan Calo). -
We are closing this season with a Spring Newsroom before we officially kick off the summer, summarizing everything that’s happened in the past quarter across our usual five sections: ePrivacy (enforcement, regulatory updates), MarTech/ AdTech, AI/ Competition/ Digital Markets, PETs/ Zero-Party Data, Future of media.
This includes:
EDPB’s ChatGPT Task Force report EU Digital Wallets Privacy Sandbox news EU Commission vs. Apple’s App Store LLM updates (Llama3, GPT 4o, Gemini, Apple Intelligence) Meta AI *not* training on EU user data Mozilla’s acquisition of Anonym Oracle’s exit from AdTech Revolut ads Microsoft Copilot+ Recall retreat The Trade Desk’s curated list of publishers FCC fines to telecom operators for the sale of location data Consent or Pay news TikTok ban.A full transcript with links and additional resources can be found on the PrivacyCloud blog.
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John Cavanaugh is a founding member of the Plunk Foundation, a non-profit dedicated to empowering individuals and communities so they have autonomy over their digital identities and protect their sensitive information. John is helping promote digital data privacy for women, children, veterans, and marginalized communities.
Our mission today: exploring a grassroots approach to privacy or data protection.
References:
Plunk Foundation John Cavanaugh on LinkedIn Doctor Ruha Benjamin, Race after Technology Village of Evendale (Cincinnati) -
Adrian Doerk is co-founder of Lissi GmbH and co-coordinator of the IDunion research project. He has extensive experience in the rollout of digital wallets, specializing in the European digital identity wallet (EUDI-Wallet) under the eIDAS 2.0 Regulation.
Adrian has helped us answer a few important questions on this topic:
How much of our lives will soon be intermediated through digital wallets or digital identities? What is “selective disclosure”? What are the privacy risks? What are the challenges of decentralization?References:
Adrian Doerk on LinkedIn eIDAS 2.0 Regulation Lissi IDunion research project -
Does the inclusion of both a private right of action and a general preemption of overlapping state laws (not limited to privacy, but also including AI or confidential information) condemn the APRA to the fire?
Brian Focht is a cybersecurity and data privacy attorney practicing in Charlotte, North Carolina. His legal practice is focused on helping clients ranging from individuals to international corporations, and involves nearly every aspect of law that touches on cybersecurity and data privacy, including identity theft, internal corporate policies and procedures, data breach response and recovery, and litigation. He is a 2003 Graduate of the University of North Carolina at Chapel Hill, a 2007 Graduate of the Wake Forest University School of Law, and a Certified Information Privacy Professional (U.S.) and AI Governance Professional.
In addition to his legal practice, he is the founder and co-host of the Fearless Paranoia podcast, which attempts to make the world of cybersecurity more accessible and understandable to those not in the IT industry. On top of that, Brian maintains the Resilience Cybersecurity and Data Privacy blog, offering tips and suggestions for keeping yourself safe in the increasingly hazardous digital world.
References:
Law Offices of Brian C. Focht Brian Focht on LinkedIn Updated text of the American Privacy Rights Act (May 2024) Biometric Information Privacy Act (Illinois) My Health My Data: Addressing the collection, sharing, and selling of consumer health data (Washington) EU-US Data Privacy Framework EFF: Sunsetting Section 230 Will Hurt Internet Users, Not Big Tech Colorado’s new AI Act (Hogan Lovells) Vermont Legislature passes data privacy bill that could shape national efforts (Vermont Public) Fearless Paranoia (Podcast)
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