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    Dec. 18, 2024

Transparency Needed, This Time in Roles for Privacy Professionals

The rapid growth of privacy risks and regulations has created a flurry of hiring, but a confusing mishmash of titles and roles, like chief privacy officer and data protection officer. As these roles develop and diversify, and the governance structures of the teams in which they are housed evolve, misunderstandings about privacy professionals’ responsibilities – and how they should work together – can lead to inefficiencies and even regulatory risk. In this guest article, Reed Smith partner Tyler Thompson and associate Talia Boiangin Behar discuss certain roles within the privacy function, reporting structures and interactions with other stakeholders. They also offer guidance on building a cohesive privacy program. See “VMware CPO Discusses the Evolution of the Privacy Role” (May 3, 2023).

Advertising Opt‑Outs Drive New Privacy Strategies in 2025

The advertising industry faces increasing scrutiny from state AGs as a growing number of U.S. individuals gain the right to directly opt out of targeted ads. Google’s abandonment in July of its antiquated plan to eliminate the third-party tracking cookie in its Chrome browser came too late to stop adtech’s switch to other cookieless personal identifiers – which are now drawing regulator interest. This article discusses Google’s promises and the looming decisions confronting adtech companies and their business users, and examines six compliance areas that adtech should consider in the coming year. It includes commentary from adtech privacy experts from BakerHostetler, the Digital Advertising Alliance, DoubleVerify, Frankfurt Kurnit, In-House Privacy, Sourcepoint and Yahoo, offered during two November panels. See “Navigating Government Investigations of Privacy Practices” (Sep. 4, 2024).

SEC Stresses Cybersecurity, AI and Crypto in Its 2025 Exam Priorities

The SEC’s Division of Examinations (Division) has spoken regarding its 2025 priorities (Priorities) – among the key focus areas are risks associated with cybersecurity, AI and other emerging technologies, and crypto assets. While Paul Atkins was selected as the new SEC Chair nominee after the Priorities were published, cybersecurity is a bipartisan issue and the SEC has built a team of talented cybersecurity experts, so it will likely remain an important exam focus, said Carlo di Florio, president of ACA Group and former Office of Compliance Inspections and Examinations Director. To help registrants as they evaluate and plan their compliance efforts for the coming year, this article provides an overview of select Priorities, with commentary from di Florio and Kristin Snyder, a partner at Debevoise & Plimpton and former Deputy Director of the Division and Head of its Investment Adviser/Investment Company Program. See our two-part series on the SEC charging four companies for misleading cyber incident disclosures: “New Expectations?” (Nov. 20, 2024), and “Lessons on Contents and Procedures” (Dec. 4, 2024).

A&O Shearman Welcomes New Cybersecurity Team Co‑Head in New York

A&O Shearman has announced that Andrew Tannenbaum will join the firm’s New York office in early 2025 as global co‑head of the cybersecurity team. He arrives from Barclays Execution Services, where he is currently serving as GC. For commentary from Tannenbaum, see “IBM Cybersecurity Counsel Offers Techniques for Speaking the Same Language as the C-Suite When Managing Cyber Risk” (Nov. 8, 2017). For commentary from A&O Shearman, see our two-part series on GDPR Enforcement’s New Phase: “More Predictability, and New Rules on the Way” (Nov. 6, 2024), and “Navigating Privacy Investigations in Europe” (Nov. 13, 2024).

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