This Privacy Regulation Roundup summarizes the latest major global privacy regulatory developments, announcements, and changes. This report is updated monthly. For each relevant regulatory activity, you can find actionable Info-Tech analyst insights and links to useful Info-Tech research that can assist you with becoming compliant.
Beyond
the Billions: What CISOs Need to Know About Accountability and Corporate Risk
Type: Enforcement
Announced: July
2025
Affected Region:
USA
Summary: A significant legal battle involving
Meta Platforms, its CEO Mark Zuckerberg, and current and former directors has
concluded with a settlement to end an $8 billion trial. The lawsuit, brought
forth by Meta shareholders, alleged that Zuckerberg and other company officials
caused substantial financial damage to the company by permitting repeated
violations of Facebook users' privacy. The allegation refers back to the
Cambridge Analytica scandal of 2019, which resulted in the company (Facebook,
at the time) being fined a record $5 billion by the Federal Trade Commission
(FTC) after discovering the company failed to comply with a 2012 agreement to
protect user data.
The undisclosed settlement terms allowed Zuckerberg and
other defendants, including former COO Sheryl Sandberg and venture capitalist
Marc Andreessen, to avoid testifying under oath in the Delaware Court of
Chancery. The $8 billion settlement will be paid by these defendants (likely
largely covered by their Directors & Officers [D&O] liability
insurance) and will be paid back to Meta itself, rather than directly to the
shareholders who initiated the lawsuit. While the agreement brings an end to a
high-stakes trial that could have delved deeply into Facebook's data practices,
its early settlement represents a missed opportunity for public accountability
and leaves fundamental questions about the company's "surveillance
capitalism" business model unresolved.
Analyst Perspective: For Enterprise IT CISOs, this
Meta privacy settlement, even without full disclosure of its terms, casts a
long shadow, setting crucial precedents and highlighting evolving risks in
corporate governance and regulatory landscapes. The core message for CISOs is
clear: data privacy failures are no longer just corporate liabilities, they are
increasingly becoming a matter of personal accountability for executive
leadership, demanding a heightened level of oversight and proactive risk
management from the security function.
Heightened Personal Accountability and D&O Liability: The "Caremark claim" at the heart of this lawsuit underscores a growing trend where directors and officers face personal accountability for systemic failures in compliance, especially concerning data privacy. While D&O insurance often covers the financial payout, the personal implication of being sued and facing potential individual liability is a significant deterrent. CISOs, as key advisors to the board on cyber risk, must ensure their reporting is robust and transparent and clearly articulates risks, mitigation strategies, and compliance status. This includes thoroughly documenting due diligence, risk assessments, and adherence to privacy-by-design principles, not just to protect the organization but also to safeguard individual executives.
Elevated Board-Level Scrutiny of Data Governance and Privacy Programs: Shareholders are increasingly recognizing privacy violations as material risks that impact company valuation and incur substantial fines. The pursuit of an $8 billion settlement highlights their willingness to hold leadership accountable. CISOs should anticipate more rigorous inquiries from their boards regarding data governance frameworks, privacy impact assessments (PIAs), and the maturity of their privacy controls. This necessitates moving beyond technical security metrics to demonstrate how privacy is embedded across business processes and product development. For CISOs in heavily regulated sectors like healthcare or financial services, this reinforces existing high compliance bars, but the precedent now extends to all industries, signaling that privacy failures can lead to significant legal and financial repercussions regardless of specific industry regulations.
Strategic Emphasis on Data Minimization and Robust Third-Party Risk Management: The lawsuit's allegations of an "illegal data harvesting operation" and the implications of the Cambridge Analytica scandal emphasize the tension between aggressive data collection and privacy obligations. Even if the settlement's monetary return to Meta is largely covered by insurance, the reputational damage and the cost of litigation are substantial lessons. CISOs must advocate for data minimization and purpose limitation as core tenets of their data strategy. Furthermore, the case underscores the critical need for strengthening third-party risk management programs. CISOs must ensure that vendors and partners with access to organizational or customer data adhere to stringent security and privacy standards, with contracts clearly defining responsibilities and liabilities, thereby mitigating both regulatory and reputational risks.
In summary, the Meta settlement serves as a potent
reminder that privacy is a continuous journey of risk management, governance,
and trust-building that extends from the CISO's office directly to the
boardroom.
Analyst: Fred Chagnon,
Principal 91制片厂 Director 鈥� Security & Privacy
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Related Info-Tech 91制片厂:
Understanding
and Governing LLM Behavior
Affected Region:
All
Summary: Hallucinations in large language models
(LLMs), where AI generates false or misleading information, are increasingly
understood to be intrinsic to how these systems function. Rather than being
eliminated through better training data or tuning, hallucinations may reflect
fundamental computational and architectural limitations in LLMs, especially in
how they predict language across vast, ambiguous inputs. Their ability to
produce fabricated outputs can even be deliberately triggered, suggesting that
unpredictability is baked into the model鈥檚 design.
This understanding shifts the focus of AI governance.
Organizations must go beyond improving data quality and adopt a
security-by-design approach. This includes input sanitization, prompt
validation, human-in-the-loop oversight, and adversarial testing that probes
for induced hallucinations. Governance frameworks like those from NIST and the
EU AI Act must evolve to assess not just performance and bias, but also
resilience to manipulation and unintended behaviors.
Effectively managing hallucinations demands more than
just regulation and tooling, it calls for cultural change. Developers and
end-users alike must understand that even confident, well-formed AI output can
be misleading. Vigilance, skepticism, and oversight are essential in
responsible AI deployment.
Analyst Perspective: Understanding that
hallucination is a built-in characteristic of LLMs, not just an occasional
glitch, changes the way we need to think about AI systems. As someone who leans
toward practical, risk-informed governance, I see this as a wake-up call for
organizations to stop chasing perfect accuracy and start designing for
resilience.
We can鈥檛 engineer our way around every anomaly, but we
can anticipate, monitor, and implement controls for them. AI governance needs
to move past data quality and model tuning and embrace a broader operational
perspective 鈥� one that includes red teaming, transparency about limitations,
and a strong human layer to catch and correct failures.
It鈥檚 not about eliminating hallucinations entirely.
It鈥檚 about recognizing them as part of the system鈥檚 behavior and putting the
right safeguards in place.
Analyst: John Donovan,
Principal 91制片厂 Director 鈥� Infrastructure and Operations
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Source Material:
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Related Info-Tech 91制片厂:
Canada鈥檚 Approach to AI Regulation
Type: Article
Published: May 2025
Affected Region: Canada
Summary: The
race for adopting effective AI governance has left many jurisdictions weighing
in on balancing AI regulation with innovation. This includes the Canadian
government. With emphasis on plans for Canada鈥檚 AI transformation, to
appointing a federal AI minister to oversee the implementation, it is evident
that Canada is aiming to be at the forefront of AI innovation.
Promoting
effective AI governance has also been part of Canada鈥檚 AI initiatives with the
development of Bill C-27. Although it is currently being examined by a
parliamentary committee, proposed amendments were presented such as introducing
new definitions for AI systems and machine learning models and aligning the
Artificial Intelligence and Data Act (AIDA) with the EU鈥檚 AI act. The proposed
amendment also clarified the definition of 鈥渉igh-impact AI systems,鈥� which AIDA
will apply to, which includes employment-related matters, biometric information
processing, and healthcare and emergency services.
AI privacy has
also been of focus by the Office of the Privacy Commissioner, with emphasis on
the development of a blueprint to inform on key privacy considerations for AI
systems. At a provincial level, various provinces have enacted new bills around
the development and use of AI. Ontario鈥檚 Bill 194, the Strengthening Cyber
Security and 91制片厂ing Trust in the Public Sector Act puts guardrails in place
around public sector AI development. Whereas Quebec鈥檚 Law 25, a privacy law
that governs how businesses handle personal information in Quebec, includes
areas on AI provisioning. The measures taken by the Ontario government, and
similarly with the Quebec government, depicts the important steps taken to
ensure AI guardrails are put in place.
Analyst
Perspective:
Canada has been one of the leading countries in AI innovation,
and now the steps taken by the government, both at the federal and provincial
level, showcases their priority in fostering safe and secure use of the
technology. The Ontario and Quebec government both enacted or modernized their
laws and due to govern the development and use of AI. This is to ensure
organizations have the right guidance in developing AI technologies, the type
of data that can be collected and its usage, as well as reducing privacy and
security risks.
At a federal
level, although it may take time before Bill C-27 is enacted, other initiatives
have been in place by the Canadian government including Canada鈥檚 voluntary code
of conduct on the responsible development and management of advanced generative
AI systems. The code, which was announced on September 2023, covers six core
principles such as accountability, fairness, and human oversight and monitoring
to ensure companies are demonstrating the responsible development and
management of generative AI systems.
With the
growing demand for consumer privacy, coupled with the advancement of AI
innovation, we can anticipate additional provinces developing laws on AI
governance. This will support Canada鈥檚 efforts on fostering innovation while
ensuring the privacy and security of Canadian consumers.
Analyst: Ahmad Jowhar, 91制片厂鈥疉nalyst, Security & Privacy
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Related Info-Tech 91制片厂:
Innovation and Safety: The AI Governance
Narrative
Type: Article
Published: June 2025
Affected Region: All
Summary: Governments are framing artificial intelligence
(AI) as a key driver of economic growth, triggering a significant shift in
global AI policy. This shift is visible across regions. Countries like Brazil
and South Korea continue to advance risk-based frameworks, similar in structure
to the EU AI Act, with tiered oversight based on use case. Whereas, Japan鈥檚
approach emphasizes government support for AI development rather than
restrictions.
The EU, often viewed as the global
standard-setter for tech regulation, appears to be balancing its rigorous AI
Act with large-scale investments and service support to encourage AI adoption.
However, the voluntary General-Purpose AI Code of Practice was published by the
European Commission in July 2025, while in the US, several policy levers are
being relaxed to foster competitiveness, which includes changes to chip export
controls.
Investments are accelerating globally
with the US leading with over $109 billion invested compared to under $20
billion in the EU. As investment surges, the policy debate is now centered on
how to capture growth opportunities without compromising on trust, fairness,
and human rights.
Analyst Perspective: The global policy narrative around AI
may be tilting toward innovation over safety. From a leadership perspective,
this shift reinforces the need for organizations to take ownership of AI risk
internally rather than waiting for regulation to dictate it. Regardless of
external policy posture, internal accountability, stakeholder alignment, and
risk mitigation must be core responsibilities for any organization building or
deploying AI.
Strategic AI governance is about enabling
safe adoption, protecting reputation, and building resilience. Organizations
that treat governance as a strategic enabler will be better positioned to
weather regulatory uncertainty, while innovating with confidence.
Analyst: Analyst: John Donovan,
Principal 91制片厂 Director 鈥� Infrastructure and Operations
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Source Material:
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Related Info-Tech 91制片厂:
Ontario's
Bill 194: Ready for Enforcement
Type: Legislation
Enforced: July 2025
Affected Region: Canada
Summary: Ontario鈥檚 Bill 194, Strengthening Cyber
Security and 91制片厂ing Trust in the Public Sector Act, 2024 (the Act),
introduces significant updates to the province鈥檚 Freedom of Information and
Protection of Privacy Act (FIPPA) and enacts a new Digital Security Act. These
reforms began taking effect in January 2025 with the FIPPA amendments becoming
fully enforceable on July 1, 2025.
The FIPPA amendments focus on three core
areas 鈥� safeguarding personal information, mandating privacy impact assessments
(PIAs), and enforcing breach notification protocols. The head of the public
sector institution must ensure that information under their custody or control
is protected throughout its lifecycle, from collection and storage to access
and disposal.
Institutions must assess privacy breaches
against a threshold known as the Real Risk of Significant Harm (RROSH).
Breaches meeting this threshold must be reported to Ontario鈥檚 Information and
Privacy Commissioner (IPC) and, where applicable, to the individuals affected.
These breaches must be recorded and communicated via an annual statistical
breach report submitted to the IPC, with the first report due by March 31,
2026.
To demonstrate transparency and
foresight, public institutions must conduct a PIA before launching any project
or practice that involves the collection of personal information. PIAs must be
provided to the IPC upon request and updated when project scope or purposes
change.
The IPC鈥檚 role as a privacy regulator has
been significantly strengthened. The commissioner now has expanded order-making
powers, including the ability to initiate reviews of institutional data
practices, compel changes to those practices, and even mandate the return,
transfer, or destruction of personal data. Reviews may be triggered by complaints
or initiated at the commissioner鈥檚 discretion.
The Digital Security Act, on the other
hand, applies to FIPPA, and the Municipal Freedom of Information and Protection
of Privacy Act (MFIPPA) covers institutions. It adds new obligations around AI
governance, and cyber resilience through measures such as encryption, identity
and access controls, patch management, and system segregation. Institutions are
expected to assess the effectiveness of these safeguards on an ongoing basis.
Analyst Perspective: The Act positions privacy as a
leadership mandate, requiring institutional heads to drive proactive risk
mitigation and transparency. With mandatory PIAs, breach notifications, and
expanded reporting obligations, the requirements mirror global best practices
tailoring to Ontario鈥檚 public sector context.
The expanded authority of the IPC marks a
notable shift 鈥� from an advisory oversight body to an enforcement regulator.
This signifies Ontario鈥檚 intent to ensure compliance and measurable
institutional responsibility. The onus of operationalizing privacy management
is explicitly placed on institutional leadership, thus by extension,
departmental and agency level teams. This further proliferates the principle of
accountability.
The Digital Security Act extends the
province鈥檚 regulatory posture to address the increasing integration of AI
systems and growing sophistication of cyber threats. While the legislative
language remains high-level, it lays groundwork for operational discipline.
The private sector may not be directly
impacted by the provisions of the Act. However, the reforms may indirectly
affect vendors and partners through contractual requirements and procurement
standards 鈥� as the Act demands operational maturity from public institutions.
Analyst: Safayat Moahamad, 91制片厂 Director 鈥� Security & Privacy
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