DOJ’s Data Security Program: Key Considerations for Compliance and Enforcement

In his piece publishing by the Journal of Internet Law, Neal Higgins discusses the Department of Justice’s new Bulk Data Rule and Data Security Program, which marks a major shift in how the US government treats sensitive personal data. The piece explains why companies allowing access to large volumes of US data, especially from abroad, face heightened compliance obligations, steep penalties and growing litigation risk. With auditing and recordkeeping requirements haven taken effect in October 2025, Neal outlines what businesses need to know.

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