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Michael Egan

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Michael Egan advises clients across various industries, including global online businesses, pharmaceutical companies, healthcare providers, manufacturers, financial institutions, sourcing providers, retail companies, and other organizations regarding the legal aspects of global privacy and data protection, data security, information technology, and related restrictions on data collection and transfer. He focuses on these issues in the context of: global company operations and applications, including websites, mobile and e-commerce applications; data security breach and incident response; transactions; litigation; internal investigations; and government inquiries. He has represented companies before numerous government authorities, including the US Federal Trade Commission, the US Department of Justice and the US Securities and Exchange Commission.

In October 2018, the Benczkowski memorandum was published reconsidering the U.S. Department of Justice’s approach to the use of corporate monitors to ensure that monitorships will not impose unnecessary burdens on businesses. Yet since then, practice shows that 50% of Foreign Corrupt Practices Act (FCPA) corporate resolutions still result in…

As the COVID-19 pandemic stretched across the globe, companies shifted to remote working environments and many reduced staff, all without much of an opportunity to prepare. The past two months have presented a serious threat to data security, including the most vulnerable financial data, personal data of employees and customers, and trade secrets. These risks cut across all sectors — financial services, industrial manufacturers, health care, and professional services. Recent experience confirms that an effective information security strategy should target these most-common threats: phishing, data sprawl, and employee mobility/redundancies.

The European Union Commission (“Commission”) has issued a report on its findings from the third annual Privacy Shield review, which took place in September. In its report, the Commission confirmed that the EU-US Privacy Shield framework continues to ensure an adequate level of protection for personal data transferred from the…

The California legislative session ended with a bang on 13 September, when legislators passed several noteworthy amendments to the California Consumer Privacy Act (CCPA). The California governor has until 13 October to act on these amendments. We have outlined below the amendments that materially alter the original scope or requirements…