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Cynthia J. Larose

Member / Co-Chair, Privacy & Cybersecurity Practice

[email protected]

+1.617.348.1732

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Cynthia is a highly regarded authority in the privacy and security field and a Certified Information Privacy Professional (CIPP). She handles the full range of data security issues for companies of all sizes, from startups to major corporations. Cynthia is masterful at conducting privacy audits; crafting procedures to protect data; advising clients on state, federal, and international laws and regulations on information use and data security; helping organizations respond to breaches; and planning data transfers associated with corporate transactions. She is an in-demand media commentator and speaker on privacy and cybersecurity issues.

Cynthia is Co-chair of the firm's Privacy & Cybersecurity Practice, a Certified Information Privacy Professional-US (CIPP-US), and a Certified Information Privacy Professional-Europe (CIPP-E).

She represents companies in information, communications, and technology, including e-commerce and other electronic transactions. She counsels clients through all stages of the corporate life cycle, from startups through mid- and later-stage financings to IPO, and has broad experience in technology and business law, including online contracting issues, licensing, domain name issues, software development, and complex outsourcing transactions. She is also a key contributor to MintzEdge, an online resource for entrepreneurs that includes useful tools and information for starting and growing a company.

Cynthia has extensive experience in privacy, data security, and information management matters, including state, federal, and international laws and regulations on the use and transfer of information, behavioral advertising, data security breach compliance and incident response, and data breach incident response planning, as well as data transfers in the context of mergers and acquisitions and technology transactions. She conducts privacy audits and risk assessments to determine data and transaction flow and to assess privacy practices, and assists with drafting and implementation of privacy policies and information security policies and procedures and monitoring of privacy best practices across all levels of the enterprise.

Cynthia is a frequent speaker on privacy issues at conferences and media appearances and presents privacy awareness and compliance training seminars to client companies.

During law school, she was editor-in-chief of the Probate Law Journal.

Cynthia is a highly regarded authority in the privacy and security field and a Certified Information Privacy Professional (CIPP). She handles the full range of data security issues for companies of all sizes, from startups to major corporations. Cynthia is masterful at conducting privacy audits; crafting procedures to protect data; advising clients on state, federal, and international laws and regulations on information use and data security; helping organizations respond to breaches; and planning data transfers associated with corporate transactions. She is an in-demand media commentator and speaker on privacy and cybersecurity issues.

Experience

viewpoints

We summarized Virginia’s Consumer Data Protection Act (CDPA) in advance of its passage by the legislature and it now awaits Governor Ralph Northam’s signature.   This will make Virginia the second state (behind California) with a comprehensive state data privacy law.   There are some key differences between the Virginia CDPA and the California Consumer Privacy Act and Consumer Privacy Rights Act (CPRA).   We will have a full analysis of the Virginia CDPA next week, so watch this space. 
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The Ongoing March toward Privacy Law in the US – A State Legislative Roundup

February 16, 2021 | Blog | By Cynthia Larose, Christopher Buontempo

Based on what we are already seeing in terms of the impressive volume of state-level proposed privacy legislation in the early days of 2021, it appears that we may see a big year for US privacy law. Below is a sampling of where things stand in Virginia, Washington, New York, Minnesota, Oklahoma, Utah, and North Dakota.
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Watch this webinar by Cynthia Larose and Susan Foster as they explore the key US national security laws that need to be taken into account, how to evaluate whether those laws potentially affect the personal data in question, potential risk mitigation measures, and how European data exporters and US data importers can work together to address these issues.
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Happy Data Privacy Day!

January 28, 2021 | Blog | By Cynthia Larose

January 28 is known worldwide as “Data Privacy Day” or “Data Protection Day,” and it’s a good opportunity to remind everyone of some privacy basics – particularly as people are still working remotely and threats to information and security increase.   Privacy and data protection is no longer “nice to have”.  It is business imperative.
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Vendor Management Fail: FTC Settles with Mortgage Analytics Company following Vendor Security Issues

January 11, 2021 | Blog | By Christopher Buontempo , Cynthia Larose

An oft-used business management concept is to “hire people smarter than you.” The concept also applies to hiring vendors – hire vendors that are better than you (especially when it comes to information security). Texas-based Ascension Data & Analytics LLC (Ascension), a technology and data analytics company used by the mortgage industry, did not utilize that concept in its vendor hiring process, and as a result, recently entered into a proposed settlement agreement with the Federal Trade Commission (FTC) following charges that it violated the Gramm-Leach-Bliley Act’s (GLBA) Safeguards Rule by failing to ensure that its third-party vendor adequately protected mortgage holder personal information.
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As businesses continue to work on compliance with the California Consumer Privacy Act (CCPA) and the multiple versions of regulations issued by the Attorney General’s Office, Attorney General Becerra has issued yet another set of proposed modifications to the regulations implementing the CCPA.  This fourth set of proposed modifications comes on the heels (and builds on) the third draft set of modifications issued in October.   That October revision had not been finalized after comments had been received. 
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Data Breaches Can Cost $$ – Plus Ongoing Obligations (ask Home Depot): Lessons and Takeaways

December 2, 2020 | Blog | By Cynthia Larose, Christopher Buontempo

The Home Depot, Inc. (“Home Depot”) recently entered into a multi-state Assurance of Voluntary Compliance with Attorneys General of 46 states and the District of Columbia (the “Settlement”) stemming from a massive 2014 data breach that exposed the payment card information of approximately 40 million Home Depot customers.  In addition to the steep penalty, Home Depot is required to undergo an extensive security overhaul.
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Earlier this week, the California Department of Justice unexpectedly released a third set of proposed modifications to the CCPA regulations. This move took place only two months after the California Attorney General’s Office “finalized” the long-awaited CCPA regulations. The latest changes relate to offline notices, “Do Not Sell My Personal Information” opt-out requests, authorized agent requests, and children’s information, as discussed below.
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California Governor Gavin Newsom has signed Assembly Bill 1281 (discussed here) to extend the California Consumer Privacy Act (CCPA) “exemptions” for business-to-business (B2B) and employee personal information.  The exemption was headed for a sunset on December 31, 2020 without legislative action, and this extension will continue through the end of 2022.  
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Kick the CCPA Compliance Program Back Into Gear

September 8, 2020 | Blog | By Cynthia Larose

2020 “back to school” has a whole new meaning in the age of COVID-19.   Now, it is finally time for companies to take compliance with the California Consumer Privacy Act (“CCPA”) off the back burner and implement policies and procedures and processes.  The California Attorney General’s final regulations are in place and approved (“Final Regulations”), and ready for enforcement. 
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News & Press

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Events & Speaking

May
1
2025

Mintz's Annual Employment Law Summit 2025 - New York

Convene, 601 Lexington Ave, New York, NY 10022

Speaker
Mar
16
2022

Hot Topics in White Collar Crime and Government Investigations: Considerations for Corporate Counsel

Association of Corporate Counsel, San Diego and Mintz

Virtual Event

Webinar Reference Image
Speaker
Feb
9
2022
Seminar Reference Image
Moderator
Speaker
Apr
27
2020
Speaker
Apr
15
2020
Webinar Reference Image
Speaker
Speaker
Mar
4
2020
Speaker
Panelist
Sep
25
2019
Moderator
Jun
19
2019

Health Care & Cybersecurity: A Powerful Combination

ML Strategies, 701 Pennsylvania Ave, NW, Suite 900, Washington, DC 20004

Speaker
Panelist
Apr
29
2019

AHAM Annual Member Meeting 2019

Know the Score

The Ritz-Carlton Washington DC

Moderator
Mar
6
2019

The Third Annual Boston Conference on Cyber Security (BCCS 2019)

Boston College, Gasson Hall, Room 100, 140 Commonwealth Avenue Chestnut Hill, MA

Speaker
Feb
4
2019

Cybersecurity Best Practices for Legal Services Providers 2019

Practising Law Institute

PLI New York Center, 1177 Avenue of the Americas, (2nd floor), entrance on 45th Street, New York, New York

Speaker
Nov
13
2018

CTAM End of Year Meeting

HBO Theater, New York, NY

Oct
3
2018

Ascendant Compliance Conference

State of the Data Breach

San Diego, California

Speaker
May
7
2018

2018 Onsolve User Conference

Arizona Biltmore Hotel 2400 E Missouri Avenue Phoenix, AZ

Speaker
Apr
18
2018

Legal Issues in Museum Administration 2018

American Law Institute Continuing Legal Education (ALI CLE)

Revere Hotel Boston Common 200 Stuart Street Boston, MA

Speaker
Mar
19
2018

2018 Cyber Liability Conference

Mohegan Sun Resort & Convention Center 1 Mohegan Sun Blvd Uncasville, CT

Speaker
Mar
15
2018

Higher Education Legal Conference

Boston Bar Association

Sheraton Boston Hotel 39 Dalton Street Boston, MA

Moderator
Mar
7
2018

The Second Annual Boston Conference on Cyber Security (BCCS 2018)

Boston College

Gasson Hall, Room 100 140 Commonwealth Avenue Chestnut Hill, MA

Speaker
Jan
19
2018
Speaker
Jan
17
2018
Speaker
Nov
30
2017
Speaker
Nov
29
2017
Speaker
Nov
28
2017
Speaker
Speaker
Nov
2
2017

Cyber Security & Liability

New Hampshire Bar Association

Concord, NH

Speaker
Oct
25
2017

Staffing World 2017

American Staffing Association

Chicago, IL

Speaker
Oct
10
2017

Ascendant Compliance Conference

Ascendant Compliance Management

Napa, California

Panelist
May
24
2017

Privacy & Cybersecurity Conference

Boston Bar Association

Boston, MA

Speaker
May
11
2017

2017 ASA Staffing Law Conference

American Staffing Association

Washington, DC

Moderator
Mar
8
2017
Speaker
Jun
3
2016

Director Bootcamp

NACD New England

Boston, MA

Speaker
May
11
2016

2016 NEDRIX Spring Conference

NorthEast Disaster Recovery Information X-Change

Boston, MA

Speaker
Dec
1
2015

Increased Scrutiny by Regulators of Cybersecurity

The New England Broker/Dealer and Investment Adviser Association

Boston, MA

Speaker
May
13
2015
Moderator
Mar
10
2015

Not If, But When: Cyber Security for Companies in an Age of Inevitable Hacks, Attacks & Breaches

National Association of Corporate Directors, New England Chapter

Newton Marriott Hotel, Newton, MA

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Cynthia is a highly regarded authority in the privacy and security field and a Certified Information Privacy Professional (CIPP). She handles the full range of data security issues for companies of all sizes, from startups to major corporations. Cynthia is masterful at conducting privacy audits; crafting procedures to protect data; advising clients on state, federal, and international laws and regulations on information use and data security; helping organizations respond to breaches; and planning data transfers associated with corporate transactions. She is an in-demand media commentator and speaker on privacy and cybersecurity issues.

Recognition & Awards

  • BTI Consulting Group Client Service All-Star (2022)

  • Best Lawyers in America: Privacy and Data Security Law (2018 – 2027)

  • Massachusetts Lawyers Weekly: Go-To Cybersecurity / Data Privacy Lawyer (2022, 2024)

  • Top Author for Cybersecurity, JD Supra’s Readers' Choice Awards (2018 – 2021)

  • Chambers USA: Noted Practitioner, Nationwide – Privacy & Data Security (2018 – 2019)

  • National Law Review: Go-To Thought Leadership Award, Cybersecurity (2018)

  • Chambers USA: Nationwide – Privacy & Data Security (2010 – 2016)

  • Chambers Global: Privacy & Data Security (2011 – 2012, 2016 – 2017)

  • Legal 500 Recommended Lawyer – Cyber Law (2026)

  • National Diversity Council: Top 50 Most Powerful Women in Technology (2016)

  • Woman of Technology 2001 by Women in Technology, Inc.

  • Two Thousand Notable American Women (2001)

  • Women's Business Boston: Top 10 Women Lawyers in Boston (2005); Top 10 Corporate Lawyers in Boston (2009 – 2010)

  • Boston Magazine: Rising Star (2011)

  • Leila Josephine Robinson Award, Boston University Woman's Law Association (2010)

  • Boston Digital Industry News: Best General Lawyer for a High-Tech Firm

  • Massachusetts Super Lawyers: Rising Star – Information Technology / Outsourcing (2005)

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Cynthia is a highly regarded authority in the privacy and security field and a Certified Information Privacy Professional (CIPP). She handles the full range of data security issues for companies of all sizes, from startups to major corporations. Cynthia is masterful at conducting privacy audits; crafting procedures to protect data; advising clients on state, federal, and international laws and regulations on information use and data security; helping organizations respond to breaches; and planning data transfers associated with corporate transactions. She is an in-demand media commentator and speaker on privacy and cybersecurity issues.

Involvement

  • Member, International Association of Privacy Professionals
  • Member, Computer Law Association
  • Member, Federal Communications Bar Association
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Cynthia J. Larose

Member / Co-Chair, Privacy & Cybersecurity Practice

Boston