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|Oops, They Did it Again: The FTC Extends the Red Flags Rule Deadline Until December 31, 2010|
Sarah Edelman Coyne, Kevin J. Eldridge, Kathryn A. Kronquist, Margaret E. M. Utterback; Quarles & Brady LLP;
June 10, 2010, previously published on June 2010Once again on the eve of enforcing the Red Flags Rule, the Federal Trade Commission (“FTC") announced on May 26, 2010, that it was extending the enforcement deadline until December 31, 2010. This time, the FTC said it was extending the deadline to give Congress time to consider H.R....
|FTC Defers Red Flags Rule Yet Again|
Kenneth K. Dort, Jonathan A. Vogel; McGuireWoods LLP;
June 9, 2010, previously published on June 1, 2010The Federal Trade Commission (FTC) announced on May 28, 2010 that enforcement of the Red Flags Rule will be further delayed until January 1, 2011, unless Congress takes steps to narrow the scope of covered businesses and legislates an earlier enforcement deadline.
|German DPAs Require Data Exporters to Verify Safe Harbor Compliance|
Hunton Williams LLP;
June 9, 2010, previously published on June 2, 2010On April 29, 2010, German data protection authorities issued a resolution regarding the obligations of German data exporters with respect to U.S. data importers that have self-certified under the Safe Harbor program. By requiring additional diligence when transferring data to Safe Harbor-certified...
|The Public Digital Bookkeeping System SPED and its Application to the Electronic Invoice NF-e Project|
Carlota Berault Moreira, Vanessa Christina Lacerda; Miguel Neto Advogados;
June 9, 2010As from January 2009, many companies of several sectors of the economy will have to adapt or get acquainted with the new requirements of the government and society when addressing a new market need, the so-called SPED (Public Digital Bookkeeping System).
|Out-of-State Exempt Organizations May be Affected by New Massachusetts Data Security Regulations|
Amy Crafts; Proskauer Rose LLP;
June 8, 2010, previously published on June 1, 2010Massachusetts’s new data security regulations, effective March 1, 2010, currently set forth the country’s most stringent requirements for protecting data. Extending beyond what is required by other states, Massachusetts specifies that, for example, covered entities, including exempt...
|FTC Again Delays Enforcement of Red Flags Rule - New Enforcement Deadline is December 31, 2010|
Erin M. Egan, David N. Fagan, Jamillia Ferris, Mark E. Plotkin; Covington & Burling LLP;
June 8, 2010, previously published on May 28, 2010Once again, on the eve of the Federal Trade Commission's (FTC's) planned enforcement of the Red Flags Rule, the Commission announced another enforcement delay, this time until December 31, 2010, for financial institutions and creditors subject to its jurisdiction. The Commission has delayed its...
|Once More unto the Breach: the UK Data Protection Regime and Action in the Event of a Data Breach|
Theo Godfrey, Richard Spiller; Edwards Angell Palmer Dodge LLP;
June 8, 2010, previously published on June 2010Any breach of the UK data protection regime can be very damaging to the business and reputation of the organisation concerned. The strength of enforcement of data protection laws and regulation is increasing, and regulated financial services firms and their executives face the threat of significant...
|Will Supreme Court's Ruling in Quon v. Ontario Yield Big Changes for Private Employers?|
Courtney H. Chacos, Benjamin Gastel, John P. Hutchins, William R. Still, James H. "Hunter" Yancey; Troutman Sanders LLP;
June 8, 2010, previously published on May 27, 2010This term, the United States Supreme Court considers a case of particular interest to those who care about privacy law. On April 19, 2010, the Court heard argument in Ontario v. Quon, U.S., No. 08-1332. A ruling is expected soon. The case is potentially important for employers who rely on written,...
|German Privacy Regulators Issue Decision on Data Protection and Safe-Harbor Self-Certification of US Companies|
Jonathan P. Armstrong; Duane Morris;
June 7, 2010, previously published on June 1, 2010A recent decision of German regulators may make compliance with privacy protections more challenging for US businesses doing business in Germany. Germany operates a regional system of data privacy regulation where each Land (or state) appoints its own regulator for the private sector. Those...
|Medical Associations File Lawsuit to Prevent Application of FTC Red Flags Rule to Physicians|
Barnes Thornburg LLP;
June 3, 2010, previously published on May 26, 2010The American Medical Association, American Osteopathic Association and the Medical Society of the District of Columbia filed a lawsuit in federal court seeking to prevent the Federal Trade Commission (FTC) from imposing on physician practices the FTC “Red Flags Rule” regarding consumer...