News & Analysis as of

The Uber Playbook: 5 Best Practices for Protecting Data Privacy

The risks are significant if managing sensitive data is not part of a proactive plan—the consequences can include penalties, sanctions and reputational damage....more

Developing a Meaningful Privacy Policy

In May 2014, California’s Attorney General Kamala Harris released recommendations for businesses addressing recent changes and best practices under California’s privacy laws. The guide is entitled “Making Your Privacy...more

Just What the Data Ordered

For Splunk, swift growth led to new policy and procedural requirements—and new legal considerations - San Francisco-based software provider Splunk’s data collection instant hit upon its debut in 2006. The software,...more

Federal Contracts: President Obama’s Executive Action Regarding Equal Pay

On Tuesday, April 8, 2014, President Obama took two executive actions, designed (in the White House’s words) “to help combat pay discrimination and strengthen enforcement of equal pay laws.” The “Fact Sheet” on the White...more

DOL Seeks Remand Of District Court Case Regarding OFCCP’s Data Gathering Authority

Earlier this week the Department of Labor moved to remand Frito-Lay’s lawsuit seeking to block the production of employment data in connection with an OFCCP investigation into discrimination at its Dallas facility. Frito-Lay,...more

BBB Warns Advertisers and Web Publishers to Take Responsibility for Behavioral Advertising Disclosures

The Better Business Bureau (“BBB”) and the Direct Marketing Association (“DMA”) are in charge of enforcing the ad industry’s Self Regulatory Principles for Online Behavioral Advertising (“OBA Principles”), which regulate the...more

Compliance Professionals And Data Analysis

Everyone knows that a compliance officer does not need to be a lawyer. Some compliance professionals believe that lawyers do not make very good compliance officers – the jury is out on that. ...more

China’s Campaign Against Bribery and Corruption Takes a New Turn: A Focus on Information Gathering

Recently, the co-founders of a firm primarily engaged in investigation-related services were arrested in Shanghai. The arrest indicates protected information laws are being rigorously enforced in China, and could signal a...more

Director Cordray gives wide-ranging testimony to House Financial Services Committee

Although the House Financial Service Committee’s hearing last Thursday was entitled “The Semi-Annual Report of the Consumer Financial Protection Bureau,” the contents of the report received little mention from committee...more

Privacy Law - Why Compliance is Crucial to Your Business

Privacy law touches the lives of all of us in different ways. To a constitutional junky, it simply provides protection from government intrusion. To A-list celebrities, it can help keep candid pictures off the front page of...more

GAO agrees to review CFPB’s data collection activities

Earlier this month, we reported that Senator Mike Crapo, Ranking Member of the Senate Banking Committee, had sent a letter to the Government Accountability Office (GAO), asking the GAO to investigate the CFPB’s data...more

House Financial Services Committee questions Antonakes about data collection

In the latest installment in the CFPB data collection controversy, the House Financial Services Committee’s Subcommittee on Financial Institutions and Consumer Credit held a hearing on July 9 entitled “Examining How the...more

Privacy Compliance = Transparency

Do you think that asking for a person’s zip code could ever result in a privacy violation? If your answer is no and you are collecting information from a resident of the District of Columbia, think again....more

Children’s Privacy and the Internet - Changes in COPPA Take Effect July 1st: Do You Comply?

What is COPPA? The Children’s Online Privacy Protection Act of 1998 (COPPA), and the COPPA Rule, 16 C.F.R. Part 312, promulgated by the Federal Trade Commission (FTC) under that Act, require that website operations...more

AML Compliance: KYC And Due Diligence

AML compliance is filled with fascinating issues, lots of acronyms, and plenty of common sense. ...more

FTC Serves Notice on App Developers About Children’s Privacy

The Federal Trade Commission has made it quite clear that it is serious about advising mobile app developers that the rules of the road will be changing very soon. Since 2011, the Commission has been working to update the...more

The 2013 Ethics and Compliance Hotline Benchmark Report

Introduction - Every year, ethics and compliance professionals gather data from the reports made through their various reporting systems. The way the data is segmented may mean the difference between catching a...more

FTC Votes to Keep July 1 Compliance Deadline for COPPA; California Bill Would Require Removing Children's Personal Information...

The Federal Trade Commission voted unanimously this week to keep the July 1, 2013, compliance date for the new COPPA Rule. Representatives from several industry groups had asked the FTC to delay the compliance date to give...more

Internet Regulation and Data Privacy in China

China is the world’s second largest economy, with an annual growth rate of more than eight percent and a rapidly growing middle class. Foreign investment into China routinely exceeds US$100 billion a year. Businesses from all...more

CMS Publishes Final Sunshine Act Rule; Data Collection to Begin on August 1, 2013

The long-awaited final rule (the Final Rule) implementing the Physician Payments Sunshine Act (Sunshine Act) has arrived at the Federal Register. It amends key definitions and adds new terms; retains broad reporting...more

FTC Provides Guidance to Mobile App Developers for Compliance with Privacy Regulations

On September 5, 2012, the Federal Trade Commission ("FTC") published a nonbinding guide directed at mobile application ("mobile app") developers, to inform developers on how to best comply with truth-in-advertising and basic...more

FTC Releases Marketing and Privacy Guide for Mobile App Developers

On September 5, 2012, the Federal Trade Commission (FTC) released a guide to help developers of mobile applications (apps) observe truth-in-advertising and fundamental privacy principles when developing, offering, and...more

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