On July 23, 2026, New Jersey Governor Mikie Sherrill signed A4085 (the Fair Price Protection Act) into law, which prohibits companies from charging consumers different prices for groceries based on their personal data. New Jersey will join New York, Connecticut, and Maryland in imposing prohibitions and requirements on the use

Continue Reading New Jersey Enacts Ban on Surveillance Pricing

On July 7, 2026, the European Data Protection Board (“EDPB”) adopted draft Guidelines 02/2026 on Anonymisation (“Guidelines”), updating a 2014 Opinion on Anonymization Techniques. While the EDPB maintains a cautious approach to anonymization, the new Guidelines appear to offer a more structured and practical framework for assessing whether information can be considered anonymous. The Guidelines are open for public consultation until October 30, 2026.

Continue Reading EDPB Publishes Draft Guidelines on Anonymisation

Consistent with recent years, 2026 has proved to be a busy year for children and teens’ privacy legislation. This post recaps notable developments and trends thus far in 2026. Our mid-year and end-of-year recaps for 2025 can be found here and here.

Continue Reading State and Federal Developments in Minors’ Privacy in 2026

On July 1, 2026, a California legislative committee advanced amendments to SB 690 that would eliminate private suits asserting website-based “pen register” claims under the California Invasion of Privacy Act (“CIPA”), leaving enforcement exclusively to the California Attorney General.  The amendments come amid a surge of lawsuits and demand letters challenging the use of website technologies under the pen register provision, which the committee described as a “poster child for abusive lawsuits.”  According to the committee analysis, “[b]ecause the potential liability can be staggering,” businesses often settle quickly, thereby “encouraging vexatious litigants to continue blasting out demand letters.”

Continue Reading California Legislature Advances Bill Targeting Wave of CIPA Pen Register Lawsuits

On June 2, 2026, Colorado Governor Jared Polis vetoed HB 26-1210, a bill that would have imposed requirements for use of “surveillance data” to set individualized prices for consumers or individualized wage setting for workers. The veto is yet another action in a trend of bills focused on regulating “surveillance” or “dynamic” pricing.

Continue Reading Colorado Governor Vetoes Overly Broad Algorithmic Pricing and Wage Setting Bill

In recent weeks, several state legislatures have amended their state comprehensive privacy laws. Some of these amendments have already been enacted into law, while others have passed their state legislature and await the governor’s signature.

Continue Reading State Comprehensive Privacy Law Round-Up: Several States Amend Their Privacy Statutes

On July 14, 2026, the Trump Administration announced the launch of a federal clearinghouse, “Gold Eagle,” that is designed to facilitate the sharing of AI-derived cybersecurity vulnerability information between government agencies, “American critical infrastructure companies,” and “open-source software partners.”  

The creation of Gold Eagle is the latest in a

Continue Reading White House Launches “Gold Eagle” AI Cybersecurity Clearinghouse

On May 27, the Connecticut governor signed into law a comprehensive artificial intelligence (“AI”) bill that regulates safety, transparency, and consumer protection, including subscription marketing (“SB 5”). Alongside key provisions on Employee Reporting Protections, AI Companions, and Automated Employment-Related Decision Technology (discussed in more detail here), SB 5 also sets

Continue Reading Connecticut Extends AI Regulation to Subscriptions

The Office of Management and Budget (“OMB”) has released its 2026 Unified Agenda, which identifies regulatory actions that federal agencies expect to propose or finalize during the remainder of the year.  Below, we highlight several notable health privacy, interoperability, and data exchange rules that the Department of Health and Human Services (“HHS”) has listed for proposed or final action in 2026.  The descriptions and target dates below reflect only the agency’s stated intentions and are subject to change.

Continue Reading OMB Publishes 2026 Unified Agenda Signaling Upcoming Health Privacy and Interoperability Updates from HHS

On July 10, 2026, New York City Mayor Zohran Mamdani and Department of Consumer and Worker Protection (“DCWP”) Commissioner Samuel Levine announced the adoption of a new “Click to Cancel” rule governing how businesses disclose, bill, and cancel subscriptions. The rule takes effect October 1, 2026.

Continue Reading New York City Adopts ‘Click to Cancel’ Rule