On December 1, 2010, the Federal Trade Commission (“FTC” or “Commission”) released a preliminary staff report (the “Report”) setting forth a framework for how commercial entities should protect consumer information.

Through this Report, the Commission seeks to inform policymakers, including Congress, in their development of solutions, policies, and potential laws governing privacy. The Report is also intended to guide and motivate the industry as it develops best practices and self-regulatory guidelines. Notably, the FTC observed that industry efforts to develop meaningful protections for consumer information have fallen short in recent years, which suggests that legislation in this area is likely warranted.