Category Archives: Dobbs

The FTC’s Post-Dobbs Focus on Location Privacy Draws a Legal Challenge

As we had previously blogged, the FTC in guidance following the Supreme Court’s decision in Dobbs v. Jackson Women’s Health indicated that it would aggressively wield its enforcement authority in relation to deceptive statements about location privacy, particularly in the context of what the FTC called “the often shadowy ad tech and data broker ecosystem.”  The FTC voiced particular concern about unbeknownst tracking or selling of sensitive location data,… More

Anonymization v. De-Identification, Post-Dobbs; Rumblings from the FTC

When is personal data “anonymized”?  The answer to this question has largely been based on jurisdiction.  If your business is in the U.S., so long as HIPAA or the CCPA does not govern, then generally aggregated or de-identified data could often be considered “anonymized” for legal compliance purposes.  (Both HIPAA and the CCPA have specific requirements for what counts as “de-identified” data.)  Under the GDPR, the story has been much more complicated:  merely “de-identified”… More