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TECHNOLOGY, AI & COMPETITION

Data breach notification

Data breach notification obligations for Technology, AI and Competition companies are tightening on multiple fronts simultaneously. The Federal Trade Commission has expanded its Safeguards Rule breach reporting requirements, the European Data Protection Board continues issuing binding guidance on 72-hour notification timelines under GDPR Article 33, and the Cybersecurity and Infrastructure Security Agency is pressing sector operators under new CIRCIA incident reporting rules that carry their own separate clock. Compliance teams are currently reconciling at least three overlapping notification windows across jurisdictions, each with different triggering thresholds and recipient lists.

Watch

  • CIRCIA proposed rules: final rulemaking timeline and covered entity scope for tech firms
  • FTC Safeguards Rule: which non-banking tech companies now fall under its breach notice trigger
  • EDPB enforcement pattern on 72-hour GDPR notifications when AI systems are the breach vector
  • State AG activity: California, New York breach notice laws diverging from federal floors

Recent material activity in Technology, AI & Competition

  • Sep 4, 2026MATERIAL

    FTC settles with payment processor Nuvei for $4.85 million over facilitated merchant fraud and tech support scams

    The FTC filed a complaint and proposed settlement order against Nuvei Corporation and four subsidiaries on September 4, 2026, for opening payment processing accounts for merchants engaged in deception. The $4.85 million …

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  • Sep 4, 2026MATERIAL

    CISA adds Google Chromium V8 type confusion vulnerability to Known Exploited Vulnerabilities catalog with federal remediation deadline of September 18 2026

    CISA added CVE-2026-85046, a type confusion vulnerability in Google Chromium V8, to its Known Exploited Vulnerabilities catalog on September 4, 2026. Federal agencies face a mandatory remediation deadline of September 18…

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  • Sep 4, 2026MATERIAL

    DOJ files proposed final judgment against KKR in antitrust consent decree proceeding

    The Department of Justice filed a proposed final judgment and competitive impact statement in United States v. KKR & Co. Inc., et al., published in the Federal Register on September 4, 2026. This filing opens the Tunney …

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  • Sep 4, 2026MATERIAL

    European Commission adopts final guidelines on exclusionary abuses of dominance, replacing 2009 enforcement priorities

    The European Commission's Directorate-General for Competition published final guidelines on exclusionary abuses of dominance on September 3, 2026. The guidelines replace the 2009 enforcement priorities paper and establis…

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  • Sep 4, 2026MATERIAL

    China's SAMR publishes second batch of administrative monopoly enforcement cases targeting local protectionism in pharmaceuticals, internet services, and coal

    China's State Administration for Market Regulation (SAMR) released the second batch of cases under its national campaign to eliminate barriers to unified market competition, published September 4, 2026. All three cases i…

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  • Sep 3, 2026MATERIAL

    FTC extends personalized pricing policy comment period by seven days to September 25, 2026

    The FTC extended the public comment deadline on its proposed enforcement policy statement on personalized pricing from September 18 to September 25, 2026. The proposed statement addresses the use of personal data to set …

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  • Sep 3, 2026MATERIAL

    FCC issues technical correction to broadband data collection final rule effective July 24, 2026

    On September 3, 2026, the FCC published a correcting amendment to its final rule on the Digital Opportunity Data Collection and modernized Form 477 broadband data program. The correction restores a defined term that was …

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  • Sep 3, 2026MATERIAL

    CMA finalizes revised merger efficiencies guidance, replacing existing assessment framework under its 4Ps reform programme

    The Competition and Markets Authority published final revised guidance on rivalry-enhancing efficiencies in mergers on September 3, 2026. The guidance replaces the existing text in the Merger Assessment Guidelines and co…

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  • Sep 3, 2026MATERIAL

    CNIL fines Hôpital Privé de la Loire €500,000 for inadequate patient data security under GDPR

    The CNIL sanctioned Hôpital Privé de la Loire €500,000 on September 3, 2026, for failing to implement adequate security measures protecting patient and related-party health data. The decision sets an enforcement benchmar…

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  • Sep 2, 2026MATERIAL

    CISA adds SonicWall SMA1000 OS command injection flaw to Known Exploited Vulnerabilities catalog with September 5 federal remediation deadline

    CISA added CVE-2026-83549, an OS command injection vulnerability in SonicWall SMA1000 Appliances, to its Known Exploited Vulnerabilities catalog on September 2, 2026. The addition imposes a federal remediation deadline o…

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