Ms. Kim is an associate in Davis Polk's Litigation Department. [Full Bio]

By now, most major U.S. companies are generally aware of the new privacy requirements that will be imposed by the California Consumer Privacy Act (“CCPA”) when it goes into effect on January 1, 2020, including data access and deletion rights for consumers as well as restrictions on selling personal information. 
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Momentum is building in Congress for federal privacy legislation and several states have their own privacy laws in the works.  But, as concerns grow that companies are collecting and sharing personal information about U.S. residents without their knowledge and not adequately protecting that data, regulators and plaintiffs aren’t waiting for
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In the last few years, we have seen a dramatic increase in the purchase and sale of alternative data—a shorthand for big data sets, such as satellite images of parking lots, drug approvals, credit card purchases, cellphone data on retail foot traffic, and construction permits. According to alternativedata.org, the alternative
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2018 was another busy year for lawyers in the privacy/cybersecurity world – GDPR, CCPA, Marriott, New York Department of Financial Service’s cybersecurity rule deadlines, increased SEC enforcement, more data breach lawsuits, more companies doing table top exercises and risk assessments, etc. But 2019 is looking to be even busier. Below
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Companies have good reasons to limit business-related communications to devices and applications (“apps”) controlled by the company, and to avoid having sensitive company information on the personal devices and apps of employees:

  • Security: The company does not control the cybersecurity and privacy on employees’ personal apps on personal devices,


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In early August, the City of Atlanta reported that the costs associated with its SamSam ransomware infection could reach $17 million, and the FBI has estimated the number of ransomware attacks may be as high as 4,000 per day. To help address the complex issue of when organizations
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