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Data Broker Audits Are Coming—And CalPrivacy Wants Your Input

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The California Privacy Protection Agency (“CalPrivacy”) has issued an Invitation for Preliminary Comments on a key upcoming...

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The California Privacy Protection Agency (“CalPrivacy”) has issued an <a href="https://cppa.ca.gov/regulations/pdf/drop_audits.pdf" target="_blank">Invitation for Preliminary Comments</a> on a key upcoming requirement under the Delete Act: independent audits of data brokers’ deletion practices. CalPrivacy is accepting comments through May 7, 2026.While the audit requirements do not come into force until 2028, CalPrivacy is shaping the audit rules now, and data brokers, consumers, and other stakeholders have the opportunity to weigh in on this process.Read the <a href="https://datadecoded.mofo.com/topics/data-broker-audits-are-coming-and-calprivacy-wants-your-input" target="_blank">full blog post</a>.

Data Broker Audits Are Coming—And CalPrivacy Wants Your Input

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Boris Segalis is a partner in Morrison Foerster’s Cyber, Data + Privacy Group. He advises companies at the intersection of data, technology, and regulation, helping them navigate complex legal frameworks while building and scaling data-driven products and services.As a leading privacy and cybersecurity lawyer, Boris’s practice is focused on issues where the law is evolving and the answers are not always clear. He works with clients to apply existing regulatory regimes to new technologies and business models, particularly in areas such as AI, data monetization, digital platforms, and emerging financial technologies. His work spans strategic product counseling, corporate transactions, and high-stakes regulatory matters, including representing companies in investigations by the Federal Trade Commission, state attorneys general, and global regulators.Clients rely on Boris for compliance advice and for practical guidance on how to operate in uncertain environments, whether designing new products, assessing regulatory risk, or responding to government scrutiny. He regularly advises on U.S. and global privacy and cybersecurity laws, including U.S. federal financial privacy laws, state privacy regimes, emerging AI requirements, and foreign privacy and cybersecurity regimes frameworks.He represents a broad range of companies, from high-growth startups to global public companies, across industries including technology, AI, financial services and Fintech, crypto, life sciences, consumer platforms, AdTech, and media.Boris has been recognized for seven consecutive years by Chambers USA in Privacy & Data Security and is also ranked by Chambers Global in Privacy & Data Security – USA. He is recognized by The Legal 500 as a leading lawyer in cyber law (including data privacy and data protection) and was previously named to Crain’s New York Business’s 40 Under 40.Boris holds a bachelor’s degree in mechanical engineering from Georgia Tech and a J.D. from New York University School of Law. He is a Certified Information Privacy Professional (CIPP/US) and has served as co-chair of the New York City KnowledgeNet chapter of the International Association of Privacy Professionals (IAPP), as well as on the IAPP Research Board. He graduated from Riga Simon Dubnow Jewish Secondary School in Riga, Latvia, in 1991.

Boris Segalis

Partner

Avy Mallik is a partner in Morrison Foerster’s Financial Services Group. His practice focuses on financial services regulation and enforcement, with a particular emphasis on emerging technologies, including fintech, artificial intelligence (AI), and digital assets.Avy advises banks, fintechs, and other financial institutions on a broad range of financial regulatory issues, including consumer protection, investor protection, payments, money transmission, banking law, BSA/AML compliance, financial privacy, and the use of emerging technologies in financial services.Before joining Morrison Foerster, Avy served as General Counsel to the California Department of Financial Protection and Innovation (DFPI), appointed by California Governor Newsom, and oversaw the office’s Legal Division, Securities Regulation Division, Broker Dealer and Investment Advisor Division, and Digital Financial Assets Law Division. In his time as General Counsel, Avy has overseen landmark legislative and regulatory initiatives, including the drafting and implementation of California’s Digital Financial Assets Law, and he has managed high profile enforcement and policy responses to major bank failures and emerging fintech issues. Previously, he served as Director of Fintech Policy for the Financial Services Committee at the U.S. House of Representatives, leading the task forces on AI in the Financial Services, Fintech, and the Digital Assets Working Group. He has also served as Assistant Attorney General for the Consumer Protection Division of the Office of the Maryland Attorney General and Director of the Foreclosure Prevention Program and Foreclosure Prevention Staff Attorney at Civil Justice.Avy is regularly invited to speak on legal and policy issues related to financial innovation and has testified before legislatures and briefed state, federal, and international policymakers on emerging regulatory challenges related to fintech products, digital assets, and AI.Avy earned his J.D. from Georgetown University Law Center and a B.A. in English Literature from Reed College.

Avy Mallik

Mary Race assists clients with a wide range of challenging privacy compliance and data security matters. Her practice focuses on managing privacy risks and helping clients develop and implement comprehensive privacy programs across a variety of industries, including tech, retail, manufacturing, advertising, social media, and communications.Mary is a go-to source of guidance on the California Consumer Privacy Act (CCPA) and other state privacy laws, as well as a thought leader on the complexities of these laws, offering clients practical compliance advice. She also counsels clients on privacy matters worldwide, including advising one of the world’s largest international companies on deploying new technologies in 40+ jurisdictions.Mary works on high-profile M&A transactions for multinational clients, such as Salesforce, the global leader in customer relationship management. She frequently advises cutting-edge startups as well as tech industry and social media giants on the privacy and data security aspects of their platforms, products, and services.Mary has a history of commitment to pro bono service. In law school, she volunteered for Pro Bono Students Canada, with a focus on environmental law and social justice.  She continues her pro bono work at MoFo, where she argued an appeal for a pro bono client before the U.S. Court of Appeals for the District of Columbia Circuit and supports pro bono clients in building out their privacy programs.Following her studies at McGill University’s Faculty of Law, Mary served as a law clerk to the Honorable Justice Louis LeBel of the Supreme Court of Canada. Prior to joining the firm, Mary was a development consultant for Human Rights Watch and taught writing at the University of Southern California.Mary is also an accomplished pianist and organist.

Mary Race

Of Counsel

Michael Paganelli is an associate in the Financial Services Group in Morrison Foerster’s Washington, D.C. office.Prior to joining Morrison Foerster as an associate, Michael served as a summer associate and paralegal in the Financial Services Group at Morrison Foerster.He has extensive experience with financial services regulation, state and federal legislation, and financial technology developments. Michael also maintains an active pro bono practice, including assisting clients with immigration matters.Michael earned his J.D. from the University of California, Irvine School of Law, where he was an associate editor of the UC Irvine Law Review. He received his B.A., summa cum laude, from The George Washington University.

Michael Paganelli

Associate

Data, Cyber + Privacy

Data Decoded