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On May 19, 2025, New York’s Office of the Attorney General (“OAG”) published new guidance on the New York Child Data Protection Act (the “Act”), which becomes effective on June 20, 2025.  As we reported last summer, the OAG released an Advanced Notice of Proposed Rulemaking addressing the Act on August 1, 2024.  The OAG has yet to release a full Notice of Proposed Rulemaking, which would be the next step in the process of developing a final rule implementing the Act’s rulemaking provisions.  Until the rules are finalized, the guidance suggests that the OAG will exercise discretion in its enforcement of the Act and consider good-faith efforts to comply with the statute.  Informal guidance is not legally binding, but provides some additional context on how the OAG might prioritize enforcement of the Act.  For a broader description of the Act’s provisions, see our previous reporting linked above. Some key elements from the guidance are listed below. Continue Reading New York Attorney General Issues Guidance on New York Child Data Protection Act

Last week, Virginia’s Joint Commission on Technology and Science held its second meeting of the Consumer Data Protection Work Group.

Instead of following a detailed rulemaking process for implementation like that provided for in the California Privacy Rights Act (CPRA), the Virginia Consumer Data Protection Act (VCDPA) is being reviewed over the next few months by a group of state officials, business representatives, and advocates. This group will publish recommendations by November 1, 2021, which the state legislature can consider if it amends the law before the VCDPA goes into effect on January 1, 2023. A stated goal of the group is to align the VCDPA with other privacy laws that states are enacting around the country.

At the meeting, the group heard public comments as well as a presentation by Deputy Attorney General Samuel Towell on behalf of the Office of the Attorney General of Virginia (OAG). The presentation covered issues that the OAG sees with the VCDPA’s implementation and proposed a number of recommendations for the group to consider:
Continue Reading Virginia Consumer Data Protection Work Group Holds Second Meeting, Hears Recommendations from the Office of the Virginia Attorney General

The Cyprus Presidency of the Council of the European Union has made clear its objective to achieve a general partial approach on certain articles of the new legislative package on data protection by December 2012, with a view to having the whole legislative package adopted in 2013 or early in…

Continue Reading Cyprus Presidency Seeking to Achieve Partial General Approach on Certain Elements of Data Protection Reform Package by December 2012

On February 11, 2026, the European Data Protection Board (EDPB) and the European Data Protection Supervisor (EDPS) (jointly, the Authorities) issued a Joint Opinion on the European Commission’s proposed Digital Omnibus Regulation (Digital Omnibus). This follows their Joint Opinion of January 20, 2026 on the Digital Omnibus on AI.

The Digital Omnibus, as with the other “omnibuses” released by the Commission, aims to streamline several EU laws, reduce administrative burdens for covered entities, and enhance competitiveness in the EU. Once adopted, it should reshape how organizations handle personal data generally, including in relation to AI development, scientific research, and incident reporting. The Authorities welcome efforts to simplify and to promote consistent interpretations of key concepts found in the GDPR, the ePrivacy Directive, the NIS2 Directive, and the remaining Data Acquis. At the same time, they caution that this initiative launched by the Commission must not weaken fundamental rights protections, including data protection.

Below is an overview of the Authorities’ positions. It covers only the key amendments discussed in our previous blog post on the Digital Omnibus.Continue Reading EU Regulators Issue Opinion on Revisions of GDPR and Other Data Laws

AI agents have arrived. Although the technology is not new, agents are rapidly becoming more sophisticated—capable of operating with greater autonomy, executing multi-step tasks, and interacting with other agents in ways that were largely theoretical just a few years ago. Organizations are already deploying agentic AI across software development, workflow automation, customer service, and e-commerce, with more ambitious applications on the horizon. As these systems grow in capability and prevalence, a pressing question has emerged: can existing legal frameworks—generally designed with human decision-makers in mind—be applied coherently to machines that operate with significant independence?

In January 2026, as part of its Tech Futures series, the UK Information Commissioner’s Office (“ICO”) published a report setting out its early thinking on the data protection implications of agentic AI. The report explicitly states that it is not intended to constitute “guidance” or “formal regulatory expectations.” Nevertheless, it provides meaningful insight into the ICO’s emerging view of agentic AI and its approach to applying data protection obligations to this context—insight that may foreshadow the regulator’s direction of travel.

The full report is lengthy and worth the read. This blog focuses on the data protection and privacy risks identified by the ICO, with the aim of helping product and legal teams anticipate potential regulatory issues early in the development process.Continue Reading ICO Shares Early Views on Agentic AI & Data Protection

On December 16, 2025, the EU Commission unveiled its proposal for the Biotech Act.  The proposal, which is only the first part of a bigger initiative for regulating biotechnologies, focuses primarily on the health sector.  The Commission took the opportunity to broadly revise the Clinical Trial Regulation (“CTR”) – see our blog post here.  In particular, it sought to better align the CTR requirements with those of the General Data Protection Regulation (“GDPR”).  This blog post provides an overview of those revisions relating to the processing of personal data during clinical trials.Continue Reading EU Biotech Act Suggests Clarifying Data Protection Rules For Clinical Trials

Last week, the Global Privacy Enforcement Network (“GPEN”)—a global network of over 30 national data protection authorities—announced the launch of its annual privacy sweep. The purpose of the sweep is to examine how websites and mobile applications commonly used by children handle minors’ personal information. Members of GPEN include regulators who have long prioritized protections for children and teens, such as the Federal Trade Commission (“FTC”), the California Attorney General, the California Privacy Protection Agency, the UK Information Commissioner’s Office, the French Commission Nationale de l’Informatique et des Libertés (“CNIL”), and the Irish Data Protection Commission.Continue Reading Global Privacy Regulators Launch Enforcement Sweep Focused on Children’s Data Protection

Over the past few months, there have been several notable developments in the cross-border data frameworks of the U.S., EU, UK, Brazil, and several Asia Pacific (“APAC”) countries. These developments reflect evolving regulatory approaches to international data flows, trade agreements, and national security priorities—each with certain nuances and particularities that multinational companies need to understand and be prepared to navigate. 

This blog post provides a brief summary of these developments and key takeaways for companies transferring personal data to or from these jurisdictions. Continue Reading Roundup of Cross-Border Data Transfer Developments