FTC Releases Annual Privacy and Data Security Update

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The FTC has released its annual report summarizing its activity during 2017 relating to privacy and data security issues.  In its self-declared role as “the nation’s primary privacy and data security enforcer,” the FTC outlines 10 privacy cases and 4 data security cases that it brought in 2017, including Uber Technologies (transportation service), Vizio (television manufacturer), Blue Global (lead generator), Upromise (college rewards program), ACDI Group (an alleged debt buyer), TaxSlayer (tax preparation service), and D-Link (wireless routers and Internet cameras).  In addition, the FTC also brought its first actions to enforce the EU-US Privacy Shield in 2017.  The FTC report also described its activities relating to international enforcement, children’s privacy, and Do-Not-Call.

The FTC also highlighted its advocacy efforts, workshops, and publications, many of which focus on what are likely future areas of FTC enforcement, such as privacy and security concerns with IoT devices, payment systems, artificial intelligence and blockchain technologies, connected cars, and student privacy.  One of the FTC’s new publications of note is its Stick with Security blog series, which offers periodic insights into key takeaways from recent law enforcement actions, closed investigations, and experiences of companies.  The FTC report also demonstrated that the agency is attempting to be flexible in light of the changing nature of identity theft, informational injuries, and modern technologies while remaining vigilant in its mission to protect consumers.  Companies should similarly remain cognizant of the FTC’s role as “one of the most active privacy and data security enforcers in the world.”

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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