E229 - Kenya Dixon, Litigation Partner at Nelson Mullins and Former Director, White House Information Governance
[00:00] Debbie Reynolds: The personal views expressed by our podcast guests are their own and are not legal advice or official statements by their organizations.
[00:12] Hello, my name is Debbie Reynolds. They call me the Data Diva. This is the Data Diva Talks Privacy podcast, where we discuss data privacy issues with industry leaders around the world with information that businesses need to know.
[00:24] Now, I have a very special guest on the show. She's actually the person, the only second person that's ever been on the show twice,
[00:33] a dear friend and colleague of mine, Kenya Dixon. She is a litigation partner at Nelson Mullins on the East Coast. Welcome.
[00:43] Kenya Dixon: Well, hello, Debbie. Thank you for having me. Twice.
[00:49] Debbie Reynolds: And I also have to say, you are the former director of White House Information Governance. So this is going to be a very interesting conversation.
[00:58] Kenya Dixon: Well, yes, I think conversations around timely, timely issues can be interesting.
[01:06] Debbie Reynolds: Well, they certainly will be today, for sure. I think there's a lot more interest or there's been a lot more talk in the news around privacy as it relates to government and government data.
[01:20] And it's so funny because a lot of times when people talk about Privacy in the U.S. they often say that the U.S. doesn't have a comprehensive privacy law federally, which is true on the consumer side, but that's not true on the government side.
[01:40] So we know that the government has a Privacy Rights act and has had it since 1974. But I would love for you to maybe tell us a little bit about that act, because now, because of some of the recent talk or activities within,
[01:58] you know, that's happening in government right now, there are a lot more news articles trying to dig up information about this. So having someone like you who has lived and breathed what this act means and all other things related to privacy and data protection, information governance, will really help the audience.
[02:17] Kenya Dixon: Well, sure. I mean, it's interesting on the federal side.
[02:21] As you said, the Privacy act of 1974 was initially enacted as a response to President Nixon's threat to use the irs, to go and use the IRS data to punish enemies and to protect friends.
[02:39] And so Congress passed this act that is a pretty comprehensive act. It's worked ever since 1974. And it is really directed at how the federal government uses and accesses pii so data about individuals in the United States, whether it's federal employees or the public.
[03:03] And so since there are so many agencies, every agency has this act overarching over the way that they use systems of record, whether those are computer systems or other ways of collecting data.
[03:19] And there is a process by which you're supposed to go about getting these New systems of record approved.
[03:28] And there are ways that you go about accessing federal data. We don't like. Typically, we don't like individuals just having access to everything.
[03:41] The statute really talks about the process.
[03:46] And I think a lot of what Doge is experiencing right now, which is a lot of the lawsuits and the pushback, has to do with the process.
[03:58] It's not so much that Doge,
[04:01] the, I don't know the four people that are placed in every agency, but those four people are reading the records of 400 million people.
[04:11] It's that there are new systems of record that they will be putting that data into, and that there's not enough information in the public domain about those systems of record.
[04:24] And there is a process for that. And I think it's difficult for people who are not of the federal government to understand all these bureaucratic processes, because they really are bureaucratic processes.
[04:38] Right. They're designed to slow down what you're doing. And what the administration's trying to do is hurry up and do it. And there may be, you know, reasons why they want to hurry up.
[04:47] One, the President has four years and not the typical extended eight years. And so they may be trying to get this. Get this done in a faster timetable. It does not mean that what they're doing will not ultimately be approved.
[05:03] So let me explain. The Privacy act has this process that you would go through when you have a new system of record, and that is any new database or whatever you're going to put data into, and you have.
[05:16] You fill that out. I've had to fill it out, you know, at more than one agency. And it wants to know what are you using the data for? How are you going to use it?
[05:24] What is the data that you're going to collect? What are all the different fields, the name, the address, the telephone number, like Social Security number. Why do you need access to all of these things?
[05:35] What it looks like is the Executive Order says, access all of it and find fraud, waste and abuse. And it says to do that within the confines of the law.
[05:46] In fact, I think the Executive Order says following, you know, to. To the extent of the law.
[05:52] So it does ask those to follow the law. And right now, what the law would require is a system of record notice, we call those sorns. And so you fill out all the information and it's published in the Federal Register.
[06:06] And then what happens is there's a comment period. Typically, you could say, well, you know, we have a need to know this information because we do want all the data in a federal repository.
[06:20] We don't want 4,000 agencies and sub agencies to all have different data and we don't have access to all of the data. We want all the data in one system of record.
[06:31] And that to me sounds like a reasonable thing for a country to do. In fact, China has done it and they have done it with our data.
[06:41] So it's interesting that China has dossiers and complete file folders of everything about us and we don't have that information in one location.
[06:54] Now people say, well, this is my private information. I don't expect DOJ and IRS and Department of Education and, you know, Department of Treasury and all these agencies to all come together and compare information on me.
[07:10] Well, they do.
[07:12] And typically there's a file that gets transferred from place to place.
[07:17] But once you file your SORN and you file and you prove that there is a need to know,
[07:24] typically after the comment period, you move forward with that action. You ask the question.
[07:30] The question is, what is Doge going to do with the data and what system are they putting this data into? And I think that hasn't been clarified because as an individual we can waive the right and we can give the government access to anything.
[07:47] But for 480 some million people,
[07:51] you're not going to get a consent from everyone. And if the government needs to do this, then the least should happen is that the process should be followed. So there's a documentation of the process.
[08:04] What system are you building or have you built? Where is that system located? Who's in charge of that system? Why do you need all this information in one location?
[08:16] And just an explanation, and that I think is what White House counsel is for, is to sit, work with Doge, fill out the sorn, explain the need to know and what is happening and why it's happening.
[08:34] And there should be a reasonable explanation for why they're doing this. Because it's very difficult to determine if there are overlapping jobs, if there are too many employees, if the people are doing the same job in multiple agencies,
[08:48] if there are people who are 150 years old that are getting Social Security. Like I don't know what all the things are that you may find in the data,
[08:59] but at the very least, document what it is that you're trying to do. And that's all. It's just the process. And I think we often see with new administrations is that their rush to get that first hundred days behind them.
[09:14] You often see that sometimes there are shortcuts and the shortcuts create some Difficulty. And I'm not talking about the firings and all of that stuff. That's very different from the Privacy act itself.
[09:26] Debbie Reynolds: Yeah. So I want your thoughts. So a couple of things that you pointed to, very interesting. And I want your thoughts. So,
[09:33] first of all, I think, because we know or have heard that they're putting this data into AI systems, Right. And people are concerned, you know, are. Is that data somehow spilling into, you know, other private company databases outside of the government?
[09:52] I think there was some talk that I had heard about people being concerned that the notices weren't going into the Federal Register comment period about what was actually being put into those databases.
[10:04] But I just want your thoughts on that.
[10:06] Kenya Dixon: Yeah, I think that's the concern. Right. It's not that the government shouldn't be updating technology,
[10:14] using new technology and trying to streamline government waste, fraud, abuse. It's that people just feel like they don't have an understanding of what is happening and who's taking advantage of the data.
[10:27] And I do think that there is an objection to the idea that Elon Musk is the person that's running that, that he would have permanent access to 480 million Americans personal data, because the Privacy act does not allow that, right, a private individual to take the federal data and put it into their private system.
[10:52] And so I think just an explanation of what's being done, what the system of record is going to be that's going to hold. It wouldn't be enough to explain to the public.
[11:05] And I think that process may take less time than all the, the resolution of all these court cases, because now what you have all these, these TROs,
[11:16] and they seem to be breaking down along political lines.
[11:20] And so, you know, how do you resolve all of that? All these cases will have to be bundled and sent to the Supreme Court, and then the Supreme Court will have to issue an order.
[11:29] And then it's very likely that the sworn process will have to be implemented anyway.
[11:35] Debbie Reynolds: Now, what's a tro?
[11:37] Kenya Dixon: Temporary Restraining Order.
[11:39] So I think how you and I decided to have this conversation is because the District Court of Maryland, in the American Federation of Teachers, et al, a series of individuals out of different federal agencies, former employees,
[11:56] veterans, a whole host of people went to the court in Maryland and said, we're being harmed by this, this very aggressive intrusion into our data. And the court agreed with them and said, the Privacy act doesn't allow for this to happen, but it's a temporary restraining order.
[12:16] And so by the middle of March, that'll be lifted and the federal government, DOGE still has to come back and say, this is what we're doing. And they have to use one of the exceptions.
[12:26] And the exception likely is a need to know to fill their job.
[12:30] But they have to explain why they need to know or have access to each of these pieces of information.
[12:36] Because pii, once you take a name and an address, that's pii,
[12:41] and if you put them in the same database and then that database is breached or an individual uses that for whatever reason, then you reached a personal right. And so I think this is really about the process and not about whether the White House has the right to create new systems of record and combine agencies and combine records.
[13:05] I don't think that's the issue. The issue is you have to follow the process. So there is some transparency. Transparency, because the executive order speaks to the idea of being more transparent.
[13:17] And so the way you get there is by publishing what it is you're trying to do.
[13:23] Debbie Reynolds: So I want your thoughts on this. And this is related to the judge's temporary restraining order. And this is a debate that happens all the time in privacy circles, and we hear it a lot.
[13:36] And that is about harm to individuals of their data being breached or accessed in some unauthorized fashion or not transparent in some way. And so the battle has been between whether it's a tangible harm or not.
[13:54] Right. So I thought it was very telling, in my view, that the judge said just the fact that this data may have been handled in some way that wasn't,
[14:06] you know, sanctioned in some way or not transparent or process hadn't been followed, that they felt that that was the harm, as opposed to other camps to say, well, something bad has to happen to you before you can prove or state that there is a harm.
[14:23] Kenya Dixon: Yeah. So when you're talking about the data of 400 million people, if the harm, if you don't do anything about the harm until after the harm has occurred, then the entire country is harmed.
[14:33] And so judges, I think, are just trying to balance,
[14:38] trying to find a balance between slow down and articulate what it is you're trying to do so that the public has time to react and respond to what it is that you're trying to do, as opposed to, we have a need to know and we're doing it right now,
[14:57] and we're not going to give you any information. You don't have a need to know about what we're going to do with your data. It's not fair to wait until there's an actual harm to everyone.
[15:07] Before you ask for just some details. And I think that's really what I think judges are having to grapple with. In the end, once the articulation is made and the soreness published in the Federal Register, there's a comment period, then I think all of this is going to move forward because there is no holding back.
[15:29] This the new way that data is going to be processed. And let's face it, our data has already been breached. I'm not saying that we don't have a right to privacy.
[15:39] I think we do have a right to privacy. I just think that there are nation states that know more information about us than, you know. Our government collects a lot of information, but doesn't really know the information, whereas China really knows the information about us.
[15:57] And so the question is, how do you balance a national interest versus individual interests in the privacy of individuals?
[16:06] And as Americans, I don't think the country has demanded a real privacy act. Right. So the privacy act that we're discussing is about how the government treats the data of individuals.
[16:19] We don't have a privacy act that's external facing. What we have instead are cybersecurity guidelines from the federal level. We have privacy guidelines and regulations at the federal level, but most of our privacy is protected at the state level.
[16:36] And so Americans have not made it a point of saying, we want you to give us more privacy protections. In fact, the stat, the case where privacy created as a right, a constitutional right, that case has been overturned.
[16:54] So we don't have this privacy right. We do have a right to make sure that the federal officials follow the 1974 Privacy act because there's been so.
[17:08] Debbie Reynolds: Much interest in this topic in the news. Are there some things I don't know about you, but when I hear certain things, I kind of cringe because I'm like, oh, that's not right.
[17:18] Or somehow people contort things or they don't fully understand what's going on or what they need to know. But is there anything that's happening that you heard in the news that you think that we can settle once and for all to set the record straight?
[17:34] Kenya Dixon: You know, there is, Stephanie.
[17:39] So just this morning, I was listening to the radio and I heard a public policy lawyer allege that during the first Trump administration that electronic data was either routinely or regularly destroyed.
[18:03] And I think that's what I was in the car and I was listening to it, and I thought, that's not true. And I know that wouldn't be true because I was in charge of electronic data from 2018 to the end of 2019.
[18:14] And it was my teams that were preparing for transition. And I know that we went above and beyond to make sure that we had preserved,
[18:26] collected,
[18:27] formatted, and transferred every piece of electronic data in the White House to the National Archives.
[18:37] Now, that process is not easy for a number of reasons.
[18:41] One of the things that we experienced in dealing with the National Archives is that they routinely say they don't have enough money, but they kept changing software.
[18:53] So to make transition easier,
[18:56] Executive Office of the President purchased the same software that the National Archives was using so that the format of all of the electronic data would be exactly the same.
[19:08] It would. The system the software would be, would be configured exactly the way the National Archives systems were configured. And that way all of the data could be seamlessly transferred, as opposed to every little batch of data being processed and configured to meet the National Archives requirements,
[19:29] which is a Herculean task. Takes a lot of employees,
[19:34] many, many hours, hundreds of hours. And it's. It's my understanding the National Archives can't even get through that data because data has exploded. So we purchased the same exact software the National Archives is using, and then the National Archives changed software again.
[19:52] So all that money down the drain. And my teams were working, and these people were working unreasonable hours and putting in Herculean efforts to process data to get it to the National Archives.
[20:08] And everything was transferred. There was no deleted data.
[20:13] We didn't go through the data and say, oh, these aren't records. Destroy them. None of that occurred. So it bothers me when I hear people allege because of these political divides, that there was something that was done by my staff, by me,
[20:35] by people who put in the effort to do the right thing, that there was something done that was inappropriate. Because I know that data was preserved, collected, and transferred to the National Archives.
[20:50] I know there's this whole hubbabaloo about what data was transferred down to Mar a Lago, but you have to remember 100% of all data is created electronically.
[21:04] There's no one typing documents with carbon paper in the White House.
[21:11] So every document was created electronically.
[21:14] Now, do paper records go through and collect documents where there's handwritten notes and sticky papers and things attached? Yes. And they make copies of those things.
[21:26] What I'm saying is that a lot of this is blown out of proportion. And because people have these conversations about records in a way that's not factual, it leads the public to believe that the people working in the White House were not doing their very best to follow, not just the letter,
[21:47] but the spirit of the law. And I think that some of that needs to be toned down. I think the American people are already uneasy and unnerved a little bit, and all of that will calm down in time.
[21:59] But intentionally getting people worked up so that they believe that records are routinely being destroyed, regardless of what side of the aisle you're on, I think is inappropriate.
[22:10] I may have misheard this public policy lawyer this morning, but I don't think I did.
[22:21] I did call the gentleman from University of Maryland because I know him personally. And I said, I do have a problem with this. And he promised that he would go back through the news story and listen for what was said and that we could write a letter to them.
[22:39] But I think it's the promulgation of the idea that people are doing something inappropriate with America's data that is problematic, because I think what we have are process issues. We don't have negative intent issues.
[22:57] And until we have proof of that, alleging negative intent is probably not the way to go. And I think we're going to see a lot of these court orders are going to.
[23:06] These temporary restraining orders will expire.
[23:10] There will be some sort of public understanding of where the data is going, what's being done with it. And then I think in 18 months, Doge will disappear, because that's what the executive order says.
[23:24] Once DOGE disappears, whatever system of record is stood up. And I have stood up systems of record. And I know that the process takes about two years for a single agency.
[23:37] So I can't even imagine how.
[23:40] And it was messy. Every time we did it, it was messy for each agency. So I can't imagine how 4000 agencies and sub agencies are going to get it done without it being a little bit messy.
[23:53] But that's, you know, that's democracy, too, to some extent.
[23:58] Debbie Reynolds: In your view, how do you think artificial intelligence complicates this issue or not the use of more emerging tech?
[24:08] Kenya Dixon: Well, I think people are unsure about artificial intelligence. I think we saw a lot more Will Smith movies before we actually had the technology.
[24:19] And so I think people are nervous with good reason.
[24:24] And I think we just need more information, that's all. I think we need more information about what system, where it is. And we don't know what the algorithm is in the IRS databases.
[24:37] I don't know that I've ever asked to see the algorithm. When I was pushing data into the cloud at different agencies,
[24:45] I wanted verification that the tools worked as they were supposed to work. And we tested them and we would have different sorts of databases to test and run trials on and sandboxes and all of that.
[25:01] And so we would do our work. Hopefully this administration is doing that and testing before putting all the data in. But the federal government overall didn't have a great,
[25:12] doesn't have a great record with new systems of record because it's so much data. And every agency has data in a different format. Data is in different applications, different systems, different types of software.
[25:31] It's all very different. I don't know what any AI tool is going to be able to do with all of that. AI is not yet my expertise.
[25:41] We will see.
[25:42] And I think, I think change is hard. I think it's hard for us to hear on the news day after day that all of this is happening. And again, I'm talking just about privacy and data.
[25:53] I'm not talking about all of the other efforts. I think it's hard for people to wrap their mind around what's being done. But I think in time this just like, I don't know if you remember after 9, 11,
[26:07] President Bush created the Department of Homeland Security and everyone was like, this is outrageous. The most outrageous thing that's ever happened. How could you create a new agency? And now Homeland Security is just Homeland Security.
[26:22] I do think AI is here. It's not going away.
[26:26] Other nation states are using it, our enemies are using it, our allies are using it, corporations are using it,
[26:33] law firms are using it.
[26:36] The federal government should get on board too.
[26:40] Debbie Reynolds: I wonder how this will complicate FOIA requests in the future.
[26:45] I just know there's an explosion of data, obviously. And so I'm just thinking out loud about what that will look like in the future.
[26:56] Kenya Dixon: You know, FOIA is an interesting,
[27:00] it's interesting because the idea is that is transparency, right? That, that you can go to an agency and get information about yourself or certain topics and that then the agency must review that.
[27:13] And right now agencies are reviewing it page by page. And as the requests get larger and the data, data that's going to be produced gets larger and larger, agencies can't keep up and FOIA departments can't keep up.
[27:26] Maybe AI is the way to do that. We see in the ediscovery world that you put data in and you get some push data analytics, but they're also using artificial intelligence now.
[27:39] We use a lot of that in litigation. Law firms jumped right on board of the AI because of the, the amount of data that we received. This is, this is here.
[27:48] It's not going away. And so FOIA should take advantage of it, too,
[27:54] I would guess. Instead of having 4,000 agencies and sub agencies search for an issue,
[28:00] having a central repository where you could put in a request and the responses and the attached documents could come out pretty quickly and you could change your search based on what the response is would be easier for the public.
[28:16] But that's going to take some time to get there. But AI is moving so rapidly. It may not take as much time as people think it, you know, think it would take.
[28:25] Debbie Reynolds: So what would be your, your thought or your advice? As people are, you know, watching the news and see all these things play out, like, what should they be thinking about or listening for?
[28:36] Kenya Dixon: Well, for one, I would take the. I would stop watching so much news. I think we watch as a nation a lot of news.
[28:45] Debbie Reynolds: We do, yeah.
[28:46] Kenya Dixon: And I think it steals some of your joy because the interesting thing about the news is it's never good news.
[28:55] Right. If it's an, if it's a story, then it's going to be something negative. And if you're not getting all the facts, the clear facts. I can't tell you how many times I sat in the White House.
[29:06] The television's on, they're reporting on something under my domain, and the story is absolutely not correct. And I don't have any idea who they spoke to to verify that story because they didn't speak to me.
[29:19] And so I think that happens. And I think that, you know, the American public would do good to, to turn some of that down a little bit. But if you have concerns about what the government is doing, you have a representative, you have a senator,
[29:33] and you can also, I would imagine you can write the president and people should participate in the process. And part of the problem in the country is so many people don't participate in the process.
[29:45] You don't participate,
[29:47] your voice won't be heard. And I mean voting and maybe writing or calling,
[29:54] I'm not talking about some of the other actions, but, but voting and selecting your candidates in a responsible manner is how a democracy works.
[30:05] So does the federal government upgrade its applications and upgrade all the agencies? Occasionally? I would think every hundred years you have to.
[30:14] Debbie Reynolds: Exactly. Because things are changing so rapidly. And then the, especially with like freedom of information,
[30:22] the,
[30:23] what is it, 25 years is the, is the time span in which the 25 years, certain records become public. Is that right?
[30:35] Kenya Dixon: Are you talking about foia? Yeah, it depends on the, it depends on what the topic is,
[30:42] the way FOIA is being used now. And this, this came about even when I was in the government is that. Let's just say you suspect one of the agencies is investigating you.
[30:54] The parties then put in a FOIA request for that information at that agency. So oftentimes FOIA is used as a discovery tool as opposed to just information about yourself.
[31:11] And so not only do you have the litigation side, meaning the discovery schedule in that investigation, or trying to carry out an investigation or litigation, then you have the FOIA side also using different rules to respond to or produce data in response to a FOIA request.
[31:30] So you have a dual track of producing data to the exact same party.
[31:35] That can be debilitating for an agency, especially after data, you know, exploded. And if you want fewer people and more accuracy and efficiency, software is how you do it. Right.
[31:48] And so maybe AI is going to help with that. Artificial intelligence, large language models. I don't know anything about what the government is choosing to use, but that typically is where you would find the efficiencies.
[32:02] Debbie Reynolds: Wow. So I would love to ask you this question which everyone talks about, and I want your thoughts. So we've been talking for many years about the possibility or not maybe, of having a federal privacy act.
[32:18] Do you think, what is your thought about the possibility of that happening in the future?
[32:26] Kenya Dixon: You know, I don't. I don't have a crystal ball. I don't know that it's high on Congress's list of things to do. I do think cybersecurity is going to get more teeth in the next 18 months.
[32:38] And cybersecurity and privacy are closely related. I think those teeth are going to be around how you protect the data that you have, how you make sure that data isn't breached or leaked, and what the requirements are for the protection of data.
[32:54] And I think that will meld to some extent the cybersecurity requirements will meld into the data privacy requirements. I think we have some very rigorous state statutes and numerous states like New York and California.
[33:13] And if you are an organization that does business nationally, you're not going to do have less data privacy or cyber security, fewer controls in place because you are in state X than you would have in state A.
[33:31] You're going to put controls in place that meet the requirements of New York and California, even if you're in 48 states.
[33:41] And so I think the majority of our protections are going to come from the state level. And I do think during this administration,
[33:49] a lot is going to be pushed back to the states and a lot of the statutes around these things will come out of the states. But look for cybersecurity teeth.
[34:00] I think that a lot of CISA made a lot of good headway with critical infrastructure sectors by identifying them and then. But they pushed all those requirements back to individual agencies.
[34:14] So there's no one place for any organization to go to find all of the CISO requirements for cybersecurity. You have to follow nist. But what, what are the individual requirements that individual agencies want you to follow?
[34:30] It's just too much to try to figure out. Right. You just can't figure it out. You can have all the in house counsel and outside counsel that you want to have.
[34:38] You can't find everything. It's not all in one place. I do think cybersecurity will end up being a White House under one of the White House components. It will have teeth and I do think that's a priority for the situation administration.
[34:51] I don't know that Congress is where we're going to see it.
[34:56] Debbie Reynolds: I agree with that definitely. The activity on the state level will definitely continue. And as you say, companies want to do business in any state or any jurisdiction, so they want to be able to align with the strictest standards so that they're not left behind for sure.
[35:15] So yeah, it's very interesting to see all these tectonic shifts, things that are happening and all these discussions. I'm actually glad that privacy is actually in the news news right now so that people can kind of.
[35:30] Yeah, so people get to talk about it and think about it and figure out, you know, what it means to them. And I totally agree that people should get involved in their democracy.
[35:39] So, you know, if you don't know who your senator is or representative, give, give them a call, send them a letter, you know, show that, that you know what your interest is.
[35:49] Because I think that's probably one of the things that's very much lacking.
[35:53] Kenya Dixon: Yeah, I think a lot of Americans are unaware that we even have a privacy act. But there's a lot of case law, you know, from 2000 forward about how, you know, how that privacy act is interpreted.
[36:06] Interpreted. But also like IRS has sections about how, you know, how you can use IRS data.
[36:13] There's a lot of law protecting your data within the federal government. What we don't have are laws protecting our data in the private sector.
[36:23] And if you think about it, the federal government has some very sensitive data about you. But private corporations have a lot of that data too. And so I think in our minds we think, oh my God, they're in our data.
[36:36] But the reality is they're already in our data and we should pay attention to that.
[36:42] Debbie Reynolds: Well, thank you so much. I'm so happy that you were able to set us straight and show up today and let us know what's going on. So I'll definitely be following this and following you and what you're doing, your career.
[36:54] And I'm so happy, happy with what you're doing and so proud of your work.
[36:59] Kenya Dixon: Thank you, Debbie. I appreciate it and thank you for inviting me. Listen. Every single day we speak to corporations and we help them with their data privacy issues. We sit down and talk to them about their web pages, their internal policies, their external facing policies, whether that not they meet international requirements.
[37:20] I have a corporation that just came to us about the new Australian Data Privacy Act.
[37:26] Every state, every country, and every state has something and we interpret that, analyze it, and help companies come up with their policies every single day. And we enjoy doing it.
[37:38] It's not hard work, but it's good work.
[37:40] Debbie Reynolds: Definitely good work. So thank you so much. I'm really happy again that we were able to chat and we'll talk soon.
[37:48] Kenya Dixon: Absolutely. I'll talk to you soon.
[37:50] Debbie Reynolds: Okay. All right. Bye. Bye.
[37:58] Kenya Dixon: It.
