September 2025

Data Privacy Frontline Report

September 2025

Here are key highlights from September 2025 detailing global news and regulatory updates.

US & Canada

  • California’s data protection authority requires company to pay a record $1.35 million fine for violating the California Consumer Privacy Act (CCPA).
  • California governor signs into law the Transparency in Frontier AI Act (TFAIA), which mandates that major AI developers publicly outline their strategies for mitigating the potentially “catastrophic risks” associated with advanced frontier AI models.
  • Nova Scotia modernizes its Freedom of Information and Protection of Privacy (FOIPOP) Act, including a more independent privacy commissioner, mandatory breach notification, and increased fines.

EMEA

  • EU European Commission releases draft guidance and a reporting template for serious AI incidents, inviting stakeholder feedback.
  • EU European Commission begins the process of adopting a GDPR adequacy decision for Brazil, aiming to enable unrestricted personal data flows between Brazil and the EU (also in LATAM).
  • EU European Commission and South Korea’s Personal Information Protection Commission (PIPC) mark the entry into force of South Korea’s adequacy decision on the EU (also in APAC).
  • EU European Data Protection Board (EDPB) issues guidelines on the interplay between the Digital Services Act (DSA) and the GDPR.
  • EU General Court dismisses challenge to annul the EU-U.S. Data Privacy Framework, upholding its validity and privacy safeguards, and providing legal certainty for transatlantic data flows amid ongoing scrutiny.
  • EU Court of Justice of the European Union (CJEU) clarifies that pseudonymized data in some circumstances may not be considered personal data under the GDPR.
  • Italy passes a new law regulating AI, making it the first EU member state to adopt comprehensive rules aligned with the EU’s AI Act.

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APAC

  • China releases version 2.0 of its Artificial Intelligence Safety Governance Framework, enhancing technical standards and reinforcing ethical review mechanisms.
  • India is expected to release final rules for the Digital Personal Data Protection Act (DPDPA) that will offer organizations a compliance framework once the DPDPA becomes enforceable.
  • New Zealand’s Privacy Amendment Act passes into law, adding the Information Privacy Principle 3A (IPP3A) to address the collection of personal information by agencies.
  • South Korea’s Personal Information Protection Commission (PIPC) and the EU European Commission mark the entry into force of South Korea’s adequacy decision on the EU (also in EMEA).

LATAM

  • Brazil’s national data protection authority becomes an independent regulatory agency provided with its own assets and legal seat in the Federal District.
  • Brazil is the focus of a new GDPR adequacy decision process initiated by the European Commission, aiming to enable unrestricted personal data flows between Brazil and the EU (also in EMEA).

Global

  • 20 data protection authorities sign a joint statement on building trustworthy data governance, acknowledging their roles in shaping data governance frameworks that address AI-related challenges.

Archiving / Destroying

Are you unleashing the full value of data you retain?

Your Challenges

Do you need help...

OUR SOLUTION

Value Retention

Client Success

Client: Comcast

Situation: California’s Consumer Privacy Act inspired Comcast to evolve the way in which they protect the privacy of customers who consent to share personal information with them.

Evaluating

Are you achieving intended outcomes from data?

Your Challenge

Do you need help...

OUR SOLUTION

Unbiased Results

Client Success

Client: Integrate.ai

Situation: Integrate.ai’s AI-powered tech helps clients improve their online experience by sharing signals about website visitor intent. They wanted to ensure privacy remained fully protected within the machine learning / AI context that produces these signals.

Accessing

Do the right people have the right data?

Your Challenges

Do you need help...

OUR SOLUTION

Usable and Reusable Data

Client Success

Client: Novartis

Situation: Novartis’ digital transformation in drug R&D drives their need to maximize value from vast stores of clinical study data for critical internal research enabled by their data42 platform.

 

Maintaining

Are you empowering people to safely leverage trusted data?

Your Challenges

Do you need help...

OUR SOLUTION

Security / compliance efficiency

CLIENT SUCCESS

Client: ASCO’s CancerLinQ

Situation: CancerLinQ™, a subsidiary of American Society of Clinical Oncology, is a rapid learning healthcare system that helps oncologists aggregate and analyze data on cancer patients to improve care. To achieve this goal, they must de-identify patient data provided by subscribing practices across the U.S.

 

Acquiring / Collecting

Are you acquiring the right data? Do you have appropriate consent?

Your Challenge

Do you need help...

OUR SOLUTIONS

Consent / Contracting strategy

Client Success

Client: IQVIA

Situation: Needed to ensure the primary market research process was fully compliant with internal policies and regulations such as GDPR. 

 

Planning

Are You Effectively Planning for Success?

Your Challenges

Do you need help...

OUR SOLUTION

Build privacy in by design

Client Success

Client: Nuance

Situation: Needed to enable AI-driven product innovation with a defensible governance program for the safe and responsible use
of voice-to-text data under Shrems II.

 

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