Although the issue has yet to be resolved by a court, the AG has publicly taken the position that “online services” include mobile apps. As we noted last month, the resolution of the Delta Air Lines case left this question unanswered.
These and other insights about the AG’s enforcement efforts were revealed at a recent event held at Paul Hastings’ San Francisco office. During that event, the AG’s Director of Privacy Education and Policy, Joanne McNabb, laid out the Department’s enforcement priorities beyond mobile privacy. According to Ms. McNabb, the AG will now turn its attention to data breaches, health information privacy, and protecting the privacy of children online. As part of that effort, the AG recently released a comprehensive data breach report summarizing the AG’s findings and recommendations about data breaches in 2012.