By Andrew D Lanphere, Catherine D Meyer, Roxane A Polidora and Jacob R Sorensen
The California Attorney General (AG) recently released a series of guidelines to assist with compliance with the California Online Privacy Protection Act of 2003 (CalOPPA), which was amended to require new data collection and ‘do not track’ disclosures. These guidelines offer assistance regarding the form and content of operators’ privacy policies. The AG has stated she will actively enforce operators’ compliance with CalOPPA, including through litigation. Operators of websites and online services that are used or visited by California residents should ensure as soon as possible that their privacy policies comply with the AG’s guidelines.
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Whoever said ‘a verbal contract isn’t worth the paper it’s written on’ did not have this quite right and recent case law confirms they actually had it quite wrong.
US: corrective action catch 22 — Court of Federal Claims holds agency action must be rational even if GAO protest decision was not
The decision in RUSH reflects the unusual circumstance in which the court effectively sat in appellate review of an earlier bid protest decision by the GAO.