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Jordan Jennings

Jordan is a member of Taft’s Privacy, Security, and Artificial Intelligence and Employment & Labor Relations practice groups. She has vast experience with technology-related issues, which brings a unique and vital perspective to her practice of successfully negotiating agreements involving personal data and developing creative governance solutions that blend well with existing business practices. Jordan’s practice focuses on the collection, processing, sharing, transferring, and retention of personal data domestically and abroad. She has experience negotiating data processing and sharing agreements for companies in various countries including those located in the European Union, United Kingdom, Asia-Pacific, and the Middle East.

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Over the past 12 months, more regulatory attention has been focused on protecting children online. In the U.S., states like California and New Jersey have recently enacted legislation designed to protect children from the dangers of AI tools like chatbots and companions, along with requiring age-appropriate design codes for online services accessible to children. On the international stage, regulators across the pond are contemplating similar legislation.

The European Commission published the proposed EU KIDS Act on September 17, 2026 (the Proposed Act). This proposal reflects the EU’s continuing effort to strengthen protections for children online by harmonizing existing EU requirements. The Proposed Act’s stated aim is to avoid a fragmented regulatory landscape that increases compliance complexity and, in turn, may impede companies’ ability to effectively protect children in practice.

While the EU KIDS Act has not yet been enacted, businesses should begin to familiarize themselves with the Proposed Act as this draft, or a version close to it, may ultimately become law.

Continue Reading Smiling Faces and Safer Online Spaces: An Overview of the Proposed EU KIDS Act

On August 2, 2026, the EU AI Act (the AI Act) entered a new implementation phase with two key developments: (i) the European Commission’s AI Office and Member State authorities began enforcing applicable AI Act requirements, including the rules for general-purpose AI (GPAI) models; and (ii) the AI Act’s Article 50 (transparency obligations) also took effect, requiring certain providers and businesses using AI to disclose when people are interacting with AI. Although the AI Act entered into force over two years ago, August 2026 marks a new chapter in its implementation. Businesses should expect increased regulatory oversight and scrutiny of AI developed, offered, or used in the EU.

Continue Reading Enforcement and Transparency Obligations Under the EU AI Act are Now in Effect

The California Information Privacy Act (CIPA) has become a go‑to vehicle for plaintiffs’ counsel attacking website tracking technologies, such as cookies, pixels, beacons, chat bots, and video or session replay tools.

Over the last few years, website operators have been hit with a wave of demand letters claiming CIPA violations. But the tide may be shifting – marking smoother sailing for website operators. A recent decision from a California court narrows CIPA to telephonic communications and significantly undercuts the viability of CIPA claims against commercial websites.

Continue Reading Changing Tides: A Los Angeles Court Delivers a Major CIPA Defense Win

Last week, on May 8, 2026, the public comment period for New York City’s own version of the “click-to-cancel rule” closed. The proposed rule (NYC Subscription Rule) was issued following an Executive Order from January 2026 by New York City Mayor, Zohran Mamdani, which focuses on ensuring New Yorkers are not forced to remain in unwanted subscriptions.

This Executive Order focuses on ensuring New Yorkers are not stuck with subscriptions. Under the Executive Order, NYC’s Department of Consumer and Work Protection (DCWP) will prioritize monitoring, investigating and taking enforcement action against subscription-related practices that deceive or mislead consumers.

Continue Reading Click‑to‑Cancel Comes to NYC: The Big Apple Cracks Down on Bad Apples (i.e., Bad Subscription Practices)

As previously reported, states such as California, Louisiana, Texas and Utah have adopted App Store Accountability (ASA) Laws. These new laws require app store operators (e.g., Apple and Google) along with app developers (i.e., the business that owns the app) to implement safeguards for age verification. While these laws are framed as child-protection measures, their impact is universal. Every app must comply, regardless of its audience. For businesses, meeting the requirements outlined in ASA Laws is mandatory for apps to remain available for download.

Louisiana, Texas and Utah’s laws are similar and take effect at various points in 2026, while California’s Digital Age Assurance Act (CA ASA Law) is unique and takes effect January 1, 2027. This is what businesses should know about the unique features of the CA ASA Law.

Continue Reading A Deeper Dive Into California’s App Store Accountability Law

As 2025 comes to a close, we asked several members of Taft’s Privacy and Data Security practice group to share their thoughts on what should be on a client’s “wish list” for the holiday season, or on a list of resolutions for 2026.

Here are their thoughts for businesses considering to not only meet the requirements of new laws and mitigate existing risks, but also looking to seize the opportunity to maximize the impact of technology to unleash the power in their data.

Continue Reading Closing Out 2025: Key Privacy & Data Security Updates from Taft

State regulators are increasingly prioritizing children’s data privacy. These efforts follow several changes to protect children’s online privacy at the federal level. One of the latest sweep of changes involve several states (e.g., California, Louisiana, Texas and Utah) imposing app store accountability laws (ASA Laws).

These new laws require app store operators (e.g., Apple and Google) along with app developers to implement safeguards for age verification, age rating, parental consent and data minimization. While the aim of these laws is to protect children, the obligations imposed on businesses apply broadly, regardless of the age of an app’s users. For businesses with mobile apps, these safeguards are not optional. They are mandatory to keep  apps available for download.

While the ASA Laws slightly vary in their respective requirements, a general overview of what businesses should know is below.

Continue Reading New App Store Accountability Laws in 2026: If Your Business Has an App, Read On

On July 1, 2025, the Virginia Consumer Data Protection Act (VCDPA) amendments took effect, implementing several changes to the existing privacy law, including adding new protections to reinforce consumers’ sexual and reproductive health information. While other consumer health data laws exist, such as Washington’s My Health My Data Act (MHMDA), which generally protects a broad category of “consumer health data,” the VCDPA amendments take a more narrow approach and only focus on reproductive and sexual health information. Here is what you need to know.

Continue Reading Virginia is for Lovers (of Privacy): VCDPA Amendments Merge Components of Consumer Data Health Laws to Better Protect Reproductive and Sexual Health Information

On June 19, 2025, the United Kingdom Parliament enacted the Data Use and Access Act 2025 (DUAA). The DUAA amends, but does not replace, the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 (DPA) and the Privacy and Electronic Communications Regulations (PECR). While the DUAA imposes new requirements on organizations subject to UK privacy legislation, it also clarifies several provisions, making privacy compliance in the United Kingdom more manageable.

The changes under the DUAA began in June 2025 and will be phased in over the next year through June 2026.

Continue Reading Are You Ready for the UK’s Data Use and Access Act 2025 (DUAA)?

Last year, we wrote about updates from the Department of Justice (DOJ) and the DOJ’s proposed enforcement efforts and regulations implementing Executive Order 14117 “Preventing Access to Americans’ Bulk Sensitive Personal Data and United States Data by Countries of Concern” (Rule).

A year later, the DOJ has finalized the Rule and developed guidance on what companies handling (i) bulk U.S. sensitive personal data or (ii) U.S. Government-related data must know, especially when interacting with persons and entities in ”Countries of Concern,” which currently include:

  • China (includes Hong Kong and Macau)
  • Cuba
  • Iran
  • North Korea
  • Russia
  • Venezuela

In April of this year, the DOJ’s National Security Division (NSD) issued its Data Security Program and corresponding Compliance Guide (DSP) and Frequently Asked Questions (FAQs) providing information that all U.S. entities must understand and follow to comply with the Rule. The NSD’s stated primary mission with respect to the implementation and enforcement of the DSP is to protect U.S. national security from Countries of Concern that may seek to collect and weaponize both government data and Americans’ most sensitive personal data.

As we have written previously, the DSP will require U.S. organizations to look deeply into their data collection and data sharing practices to determine whether they are (i) providing covered data to a Country of Concern and (ii) subject to the DSP’s requirements.

All U.S. organizations handling government-related data and bulk U.S. sensitive personal data must make good-faith efforts to comply with the DSP by July 8, 2025.

Continue Reading One Month to Go: What You Need to Know about the U.S. Department of Justice’s Data Security Program