On October 21, 2025, the New York State Department of Financial Services (“NYDFS”) issued an industry letter (the “Guidance”) highlighting the cybersecurity risks related to Covered Entities’ use of Third-Party Service Providers (“TPSPs”) and providing strategies to address these risks. The Guidance is addressed to all Covered Entities subject to NYDFS’s cybersecurity regulation codified at
Inside Privacy
Updates on developments in data privacy and cybersecurity
China Amends Cybersecurity Law and Incident Reporting Regime to Address AI and Infrastructure Risks
Over the past few months, Chinese regulators have taken steps to update the country’s cybersecurity framework, with a particular focus on artificial intelligence (AI) safety and clarifying incident reporting obligations for onshore infrastructure. These developments reflect a broader trend toward more proactive AI and cyber governance and could signal priorities for the year ahead.…
European Commission Publishes Apply AI Strategy to Accelerate Sectoral AI Adoption Across the EU
On 8 October 2025, the European Commission published its Apply AI Strategy (the “Strategy”), a comprehensive policy framework aimed at accelerating the adoption and integration of artificial intelligence (“AI”) across strategic industrial sectors and the public sector in the EU.
The Strategy is structured around three pillars: (1) introducing sectoral flagships to boost AI use…
EU Member States Begin Rolling Out New Product Liability Rules
By December 9, 2026, all EU Member States must update their product liability laws to align with the (new) Product Liability Directive (EU) 2024/2853 (“PLD”). The PLD imposes liability on manufacturers of products (and other relevant parties) for harm caused by defective products, regardless of fault. The PLD modernizes the current EU product liability framework…
California Enacts New Privacy Laws
Recently, California Governor Gavin Newsom signed into law several privacy and related proposals, including new laws governing browser opt-out preference signals, social media account deletion, data brokers, reproductive and health services, age signals for app stores, social media “black box warning” labels for minors, and companion chatbots. This blog summarizes the statutes’ key takeaways.
- Opt-Out
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Navigating California’s New and Emerging AI Employment Regulations
The California Civil Rights Council and the California Privacy Protection Agency have recently passed regulations that impose requirements on employers who use “automated-decision systems” or “automated decisionmaking technology,” respectively, in employment decisions or certain HR processes. On the legislative side, the California Legislature passed SB 7, which would impose additional obligations on employers who…
Commission Collects Feedback to Simplify Rules on Data, Cybersecurity and Artificial Intelligence in Upcoming Digital Omnibus
On September 16, 2025, the European Commission launched a call for evidence to collect feedback and best practices on simplifying several key areas of the EU digital rulebook, ahead of its planned Digital Omnibus package. This initiative targets legislation related to data, cybersecurity, and artificial intelligence, aiming to reduce administrative burdens and compliance costs for…
European Parliament Study Recommends Strict Liability Regime for High-Risk AI Systems
On July 24, 2025, the European Parliament (EP) published a study entitled Artificial Intelligence and Civil Liability – A European Perspective. The study considers some of the EU’s existing and proposed liability frameworks, notably the revised Product Liability Directive (PLDr) and the AI Liability Directive (AILD), which was proposed by the European Commission…
Italian Garante Adopts Statement on Health Data and AI
On July 30, 2025, the Italian Data Protection Authority (“Garante”) released a statement addressing the risks of using AI to interpret medical data. In this statement, the Garante recognizes the growing trend of individuals uploading medical analyses, X-rays, and other reports onto generative artificial intelligence platforms to obtain interpretations and diagnoses. It warns users of…
Help Shape the New EU Consumer Protection Law: Join the Public Consultation on the Digital Fairness Act
On July 17, 2025, the European Commission launched a “call for evidence” and public consultation on the Digital Fairness Act (“DFA”), an anticipated new consumer protection law. The Commission seeks feedback on existing EU consumer protection laws and on proposals for how the DFA could address the following two problems with the existing…