A Look at Recent Federal Trade Commission and Consumer Financial Protection Bureau Initiatives Concerning Privacy and Data Security

Ballard Spahr LLP
Contact
Our discussion examines the FTC’s Advanced Notice of Proposed Rulemaking relating to what it describes as “commercial surveillance” and the CFPB’s circular confirming that covered persons and service providers may violate the Consumer Financial Protection Act’s prohibition against unfair acts or practices when they fail to adequately safeguard consumer information. We consider the ANPR’s scope, its areas of focus, and potential federal and state obstacles to the FTC’s initiative. After providing an overview of the CFPB’s circular, See more +
Our discussion examines the FTC’s Advanced Notice of Proposed Rulemaking relating to what it describes as “commercial surveillance” and the CFPB’s circular confirming that covered persons and service providers may violate the Consumer Financial Protection Act’s prohibition against unfair acts or practices when they fail to adequately safeguard consumer information. We consider the ANPR’s scope, its areas of focus, and potential federal and state obstacles to the FTC’s initiative. After providing an overview of the CFPB’s circular, we look at the data security measures highlighted by the CFPB, the CFPB’s authority to address data security, precedents to which companies can look in assessing the adequacy of their data security measures and potential exposure, and steps to mitigate risk.

Alan Kaplinsky, Ballard Spahr Senior Counsel, hosts the conversation, joined by Greg Szewczyk, Co-Leader of the firm’s Privacy and Data Security Group, and Tim Dickens, an associate in the firm’s Litigation Department focusing on privacy and data security. See less -

Embed
Copy

Other MultiMedia by Ballard Spahr LLP

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Ballard Spahr LLP | Attorney Advertising

Written by:

Ballard Spahr LLP
Contact
more
less

Ballard Spahr LLP on:

Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
- hide
- hide

This website uses cookies to improve user experience, track anonymous site usage, store authorization tokens and permit sharing on social media networks. By continuing to browse this website you accept the use of cookies. Click here to read more about how we use cookies.