Photo: Chris Ratcliffe/Bloomberg Overlapping Authority in Cybersecurity Enforcement Actions Creates Risk
The risk of overlapping jurisdiction in the data protection space increases both with the frequency of reported breaches and the adoption of new data protection regimes in the various states. This overlapping authority and jurisdiction can lead to so-called "piling on," where one investigation by or settlement with a regulatory authority is followed by another. Case in point, the recent EyeMed consent order, entered into by EyeMed Vision Care and the New York State Department of Financial Services.
November 22, 2022 at 10:00 AM
8 minute read
Risk and Compliance
Data protection regulation in the United States is famously fragmented. A patchwork of federal and state requirements overlap, and periodically conflict, when it comes to the protection of consumer data. And these overlapping regulatory regimes do not even agree when it comes to the definition of "consumer."
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