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Hello all, and happy Thursday!

The Osano team is back from Thanksgiving break, recharged and ready to support your compliance. And as always seems to happen when the holiday season comes around, privacy news has ramped up.

The story that caught my eye recently is November’s multi-state enforcement against Illuminate Education for $5.1 million. Back in 2021, Illuminate suffered a data breach that exposed millions of students’ data. Follow-on investigations revealed severe security failures on Illuminate’s part, such as failing to inactivate former employees’ credentials, to monitor for suspicious activity, and to secure backup databases.

The aspect of this action that I wanted to draw attention to was its multi-state, collaborative nature. California’s, Connecticut’s, and New York’s AGs teamed up on this one. 

Even when an investigation doesn’t yield a multi-state penalty, it’s important to remember that state AGs are talking to one another about privacy–they’re sharing lessons learned, tactics, and planned initiatives. It’s yet another reason why we’ve seen privacy enforcement pick up so quickly in the US in the past year. With 2026 right around the corner, I’ll be curious to see if the momentum continues.

Best,

Arlo

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CalPrivacy Launches Data Broker Enforcement Strike Force

The California Privacy Protection Agency (CalPrivacy) is creating a Data Broker Enforcement Strike Force within its Enforcement Division to investigate privacy violations by the data broker industry. The Enforcement Division will be reviewing the industry for compliance with the data broker registration requirement in the Delete Act, as well as for compliance with the state’s comprehensive privacy law, the California Consumer Privacy Act (CCPA).

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Connecticut, California, and New York Reach Landmark Settlement for Student Data Breach

Recently, Connecticut Attorney General William Tong, California Attorney General Rob Bonta, and New York Attorney General Letitia James announced a significant settlement stemming from the enforcement of the states’ respective privacy laws. Due to failures to protect student data exposed following a data breach in 2022, Illuminate Education has agreed to pay $5.1 million to settle its violations.

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Attorney General Bonta Secures $1.4 Million Settlement with Mobile App Gaming Company for Violating California's Nation-Leading Privacy Law

California Attorney General Rob Bonta recently announced a settlement with Jam City, resolving allegations that the mobile app gaming company violated the CCPA by failing to offer consumers methods to opt out of the sale or sharing of their personal information across its apps. In addition to $1.4 million in civil penalties, Jam City must provide in-app methods for consumers to opt out of the sale or sharing of their data and must not sell or share the personal information of consumers at least 13 and less than 16 years old without their affirmative opt-in consent.

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EU Justice Chief Draws Red Line on Privacy Reforms

The European Commission went as far as it could with its pro-business data protection reforms without putting Europeans' privacy on the line, says Justice Commissioner Michael McGrath. "We are close to, or at the point, where significant further changes could put at risk those high standards of data protection that I think we hold dearly in the European Union.” The Digital Omnibus proposal, released in November, has drawn criticism from privacy advocates for being excessively pro-business already.

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India's Digital Personal Data Protection Act Now in Effect

With the Ministry of Electronics and Information Technology's 13 Nov. official notification of the Digital Personal Data Protection Rules, 2025, India's Digital Personal Data Protection Act (DPDA) has come into effect. Though the DPDPA passed 11 Aug. 2023, it was not operational until the notification of the rules, as timelines specifying its applicability were relegated to be outlined in the rules.

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