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Natalie Dugan

Natalie Dugan is an associate in the firm’s Washington, DC office and a member of the Data Privacy and Cybersecurity Practice Group.

Natalie advises clients on a broad range of data privacy and cybersecurity issues and across industries. Natalie’s practice includes helping clients comply with existing and emerging state privacy laws, such as the California Consumer Privacy Act and the California Privacy Rights Act, along with federal privacy frameworks such as those set forth by the Federal Trade Commission and consumer protection laws and guidance.

With a focus on AdTech and related privacy issues, Natalie routinely partners with clients to develop privacy notices and choices, draft and negotiate privacy terms with vendors and third parties, and design related governance programs and new products. Additionally, Natalie helps clients strategically engage with and respond to privacy-related inquiries from regulators like the FTC, the California Privacy Protection Agency, and state attorneys general.

Natalie also counsels clients on various other technology-related consumer protection issues, such as state “right-to-repair” legislation and anti-tying warranty provisions under the Magnuson-Moss Warranty Act.

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In late November, the Federal Trade Commission (“FTC”) released a staff perspective paper (“the Paper”) detailing the results of an FTC study that surveyed 184 “smart” devices, ranging from smartphones to hearing aids to door locks, to determine whether manufacturers disclose how long they provide software updates for their products and related apps. Without such updates, according to the Paper and the corresponding press release, these products “may lose their ‘smart’ functionality, become insecure, or completely cease to operate.”Continue Reading FTC Staff Paper Finds Most “Smart” Products Manufacturers Fail to Disclose How Long They Will Provide Software Updates

The New York Office of Attorney General (OAG) recently published guidance for website privacy controls. Although New York does not have a comprehensive privacy law, business’ privacy-related practices and statements may be subject to New York’s consumer protection laws, which generally prohibit businesses from engaging in deceptive acts and practices. Accordingly, the OAG noted that “statements about when and how website visitors are tracked should be accurate, and privacy controls should work as described.”Continue Reading New York AG Issues Guidance on Website Privacy Controls

On January 18, 2022, a New Jersey bill which prohibits employers from making use of tracking devices in vehicles operated by employees without providing written notice was passed into law. See Assembly Bill A3950. Effective April 18, 2022, the law will subject employers that knowingly make use of a “tracking device” in a vehicle used by an employee without providing written notice to the employee to civil penalties not exceeding $1,000 for the first violation and not exceeding $2,500 for the second violation. Id.
Continue Reading New Jersey Law Requires Employers to Provide Notice Before Tracking Vehicles

Early last week, Senator Cory Booker (D-NJ) and Congresswomen Anna Eshoo (D-CA) and Jan Schakowsky (D-IL) introduced a new bill, the Banning Surveillance Advertising Act, which would prohibit ad tech companies and other advertisers from engaging in targeted or “surveillance” advertising.  Targeted advertising is defined under the bill as…
Continue Reading Congressional Democrats Introduce New Bill Banning Targeted Advertising