Life just got a lot more confusing, complicated and expensive for organizations that transmit personal data to the United States from the European Union (EU) under the frequently-used U.S. – EU Safe Harbor program. Why?...more
10/7/2015
/ Data Protection Authority ,
EU ,
EU Data Protection Laws ,
European Court of Justice (ECJ) ,
International Data Transfers ,
National Security ,
Personal Data ,
Popular ,
Privacy Policy ,
Safe Harbors ,
Umbrella Agreement ,
US-EU Safe Harbor Framework
In a highly-anticipated decision, the U.S. Court of Appeals for the Third Circuit has ruled in FTC v. Wyndham Worldwide Corporation that the Federal Trade Commission (“FTC”) is authorized to pursue lawsuits against those who...more
8/27/2015
/ Administrative Authority ,
Consumer Information ,
Cybersecurity ,
Data Breach ,
Data Privacy ,
Data Security ,
Federal Trade Commission (FTC) ,
FTC v Wyndham ,
Privacy Policy ,
Unfair or Deceptive Trade Practices ,
Wyndham
In Part 1, we covered some basic privacy policy concepts. Here in Part 2, we address three problems associated with privacy policies in practice.
1. You Don’t Have One, But You Really Should -
There is no...more
A privacy policy is a key legal document in this new era of Big/Data/Breaches. When distilled to its essence, a privacy policy is simply “say what you do, and do what you say” with others’ personal information. A growing...more
Companies that are looking to sell, transfer or buy personally identifiable information (“PII”) via bankruptcy asset sales would be wise to confirm that such a transfer is consistent with the debtor’s privacy policy. If it...more