The Bulk Sensitive Data Rule: The First Year

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The “Preventing Access to U.S. Sensitive Personal Data and Government-Related Data by Countries of Concern or Covered Persons” rule – also known as the Bulk Data Rule - was published on January 8, 2025,  as directed by Executive Order 14117.  Most of the Bulk Data Rule was in force as of April 8, 2025, and the rest on October 6, 2025.  During the 18 months since the Bulk Data Rule was published, many multi-national businesses have considered how to comply – revisiting data transfers, establishing compliance programs and restructuring.  Meanwhile, last Fall, the Bulk Data Rule started showing up in lawsuits base on allegations that the collection of marketing data without consent and subsequent transfers to “covered persons” violate federal and state wiretapping laws, which offer private rights of action, and the Bulk Data Rule.  If the lawsuits are successful, plaintiffs can recover statutory damages, representing a significant sum.  Join this webinar to learn about how the Bulk Data Rule applies in practice and its role in recent lawsuits, as well as what we anticipate moving forward.

Learning objectives:  Review the Bulk Data Rule’s requirements and how it interrelates with the Protecting Americans’ Data from Foreign Adversaries Act of 2024 and state law initiatives, hear about key compliance and risk considerations for U.S. organizations; and learn how the Bulk Data Rule is used in litigation.

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