The Federal Trade Commission ("FTC") is working hard to make sure consumers are not being misled about how websites and social networking sites are using their personal information. Companies that do not follow their own privacy policies are finding themselves the subject of FTC complaints. It is therefore even more important for businesses to review and update their "privacy policy," "terms of use," and other legal agreements on their websites. This review should also include any company apps.

The recent consent decrees that the FTC entered into with Facebook, Google and online advertiser ScanScout highlight the need for businesses to make sure they are acting in accordance with their privacy policies. Businesses are well advised to take the following actions...