On November 29, 2011, the Federal Trade Commission (“FTC”) announced a proposed order against Facebook that builds upon the recommendations it made in the draft privacy report it released a year ago, as well as on precedents it set in the order it recently imposed on Google Inc. Any business that collects personal information from consumers should pay close attention to this action because it makes it clear that:

•The FTC will continue to remain vigilant in holding companies to their privacy promises. It will pay particular attention when those promises involve consumers’ choices regarding their personal information, and it will continue to look for and prosecute companies’ failures to abide by the principles underlying their US/EU Safe Harbor certifications...