Data Matters In Cybersecurity

The European Union’s (“EU”) Digital Operational Resilience Act (“DORA”) became effective on 17 January 2025. Since then, financial entities (such as banks, insurance companies and investment firms) and their ICT third-party service providers operating in the EU have been – directly or indirectly – subject to the new regime. One of the first key DORA compliance deadlines, for financial entities to register their ICT service providers with competent EU Member State authorities, is coming into effect across most of the member states this month. The post Financial Entities in the EU: Time to Register Your ICT Third-Party Service Providers under DORA appeared first on Data Matters Privacy Blog.

On April 9, 2025 the European Commission adopted a communication on the so-called AI Continent Action Plan – its strategy to shape the next phase of AI development in Europe, with consultation to follow. The Commission’s declared objective is to transform the EU into a global leader in AI by fostering innovation, ensuring trustworthy AI, and enhancing competitiveness while safeguarding democratic values and cultural diversity. Keep monitoring Data Matters for more on the Commission’s consultation, when available. The post EU Commission Publishes AI Continent Action Plan and Seeks Input appeared first on Data Matters Privacy Blog.

Consumer protection is rising to the top of the regulatory agenda worldwide. The UK consumer protection regime is undergoing a major shift: The Competition and Markets Authority (CMA) now has powerful new tools under the Digital Markets, Competition, and Consumers Act (DMCCA) (see our Sidley Update here), including the ability to directly enforce consumer law and fine companies up to 10% of global annual turnover for serious infringements. The post New UK Consumer Rules Herald Stricter Enforcement and Significant Fines appeared first on Data Matters Privacy Blog.

For Swiss companies, the next six months are critical for preparing to meet new Digital Data Law obligations. In this briefing, we outline the key timelines, compliance requirements, and practical steps to align with EU requirements. The post Meeting EU Data, Cybersecurity, and Artificial Intelligence Law Obligations: A Checklist for Swiss Life Sciences Companies appeared first on Data Matters Privacy Blog.

On February 12, 2025, the Swiss Federal Council unveiled its long-awaited approach to artificial intelligence (AI) regulation. Instead of adopting a comprehensive AI Act like the European Union, Switzerland has opted for a sector-specific framework, integrating AI considerations into existing laws rather than creating a standalone regulatory regime. The post New Pathway of Regulating Artificial Intelligence in Switzerland: Competitive Edge or Challenge? appeared first on Data Matters Privacy Blog.

The newest editions of the Chambers Global Practice Guides have been published. Sidley lawyers have contributed to: Cybersecurity 2025. The post Chambers 2025 Global Practice Guide for Cybersecurity appeared first on Data Matters Privacy Blog.

On March 14, 2025, the U.S. Department of Health and Human Services (HHS) issued a revised Statement of Organization for the Office of the General Counsel (HHS-OGC).1 Changes include a return to an organizational structure more like the early days of the first Trump administration for the lawyers advising the Food and Drug Administration (FDA), as well as the closing of certain regional HHS-OGC offices. Additional changes could potentially signal an effort to consolidate and expand HHS-OGC’s authority, especially with respect to matters currently opined upon by lawyers advising the HHS Office of Inspector General (HHS-OIG). Stakeholders should consider opportunities to engage with HHS in light of the changes announced in the March 2025 Statement of Organization. The post U.S. HHS Office of General Counsel Statement of Organization Suggests Potential Consolidation, Expansion of Authority appeared first on Data Matters Privacy Blog.

In a significant development in the ever-expanding world of privacy class actions, earlier this month a federal judge in Florida denied dismissal of a website privacy claim brought under the Florida Security of Communications Act (FSCA). For years, Florida courts have been reluctant to find that this 50-year-old wiretapping statute could be applied to third-party technologies that analyzed consumer behavior on websites. When a wave of privacy class actions was filed under the FSCA a few years ago, the claims were almost uniformly rejected, as the courts found that the information allegedly intercepted by website technologies had little resemblance to the contents of a wiretapped telephone call. But on March 6, a district court in the Middle District of Florida took a new look at some of the latest website technologies and, in doing so, may have thrown the FSCA back into the mix of decades-old statutes that pose new dangers to consumer-facing websites. The post Florida Federal Court Puts Florida’s Security of Communications Act in Play in the Ongoing Wave of Website Privacy Class Actions appeared first on Data Matters Privacy Blog.

The final rule on the new U.S. outbound investment security program (Outbound Investment Rules), implemented by the U.S. Department of the Treasury (Treasury) and effective on January 2, 2025, represents a significant regulatory framework aimed at prohibiting, or requiring notification to Treasury of, investments directed by, or undertaken by subsidiaries of U.S. persons in Chinese-affiliated companies that design, develop, or manufacture certain sensitive technologies deemed important to U.S. national security. Understanding the implications of the Outbound Investment Rules will be essential for both borrowers and lenders operating within these jurisdictions. The post Impact of U.S. Outbound Investment Rules on Loan Transactions in China and Practical Considerations appeared first on Data Matters Privacy Blog.

On February 12, 2025, the European Insurance and Occupational Pensions Authority (“EIOPA”) published a consultation on its draft opinion on artificial intelligence (“AI”) governance and risk management (the “Opinion”). The post EIOPA Publishes Consultation on Opinion on AI Governance and Risk Management appeared first on Data Matters Privacy Blog.