News & Analysis as of

Data Breach Consent Order

Robinson+Cole Data Privacy + Security Insider

FTC Order with GoDaddy Finalized Over Lax Data Security

On May 21, 2025, the Federal Trade Commission (FTC) finalized its order with GoDaddy over allegations that GoDaddy “failed to implement standard data security tools and practices to protect customers’ websites and data.” In a...more

Wyrick Robbins Yates & Ponton LLP

Something Old, Something New: Latest NYDFS Cybersecurity Regulation Enforcement Action Emphasizes Policy Implementation, Training,...

The New York State Department of Financial Services recently announced that it has entered into a consent order with PayPal, Inc. for violations of the NYDFS Cybersecurity Regulation. The consent order, under which PayPal has...more

Goodwin

New York Department of Financial Services Reaches $2,000,000 Settlement with Peer-to-Peer Payment Platform

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On January 23, 2025, the New York Department of Financial Services (DFS) announced that it reached a $2,000,000 settlement as part of a broader consent order with a peer-to-peer payment platform (“P2P”) about its...more

Goodwin

51 State Financial Regulatory Agencies Enter Settlement and Consent Order with Nonbank Mortgage Servicing Companies

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​​​​​​​​On January 9, 2025, 51 State Financial Regulatory Agencies (the “Agencies”) announced a coordinated consent order and settlement agreement with nonbank mor​tgage servicing companies (the “Companies”). ...more

Perkins Coie

FTC and State Coalition Settle Data Breach Cases with Marriott

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The Federal Trade Commission (FTC) announced a complaint and proposed consent order against Marriott International Inc. and its subsidiary, Starwood Hotels & Resorts Worldwide LLC, on October 9, 2024, concerning three alleged...more

Troutman Pepper Locke

More Privacy, Please – February 2024

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Editor’s Note: In recent regulatory and enforcement developments, the White House announced a new executive order aimed at strengthening cybersecurity at U.S. ports, and another executive order was issued to protect sensitive...more

Troutman Pepper Locke

More Privacy, Please - September/October 2023

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Editor’s Note: The FTC continues to crack down on privacy and cybersecurity, including issuing a new warning to tax preparation companies and entering into a consent decree with 1Health.io. VPPA and BIPA litigation continues...more

Harris Beach Murtha PLLC

Recent New York Cybersecurity Enforcement Provides Latest Reason for Companies to be Proactive

New York’s Department of Financial Services signaled once again its intent to strongly enforce the state’s Cybersecurity Regulation by finding OneMain Financial Group violated the law in several ways and imposing a $4.25...more

Epiq

Minimizing Data to Minimize Exposure: Information Governance and Data Security Overlap

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How important is it for organizations to keep track of their data footprint? The Federal Trade Commission (FTC) thinks this is crucial. On Jan. 9, 2023, the FTC finalized a consent order following a breach. The order was...more

Snell & Wilmer

Federal Trade Commission Finalizes Order Holding Drizly, LLC and Its CEO Accountable for Data Security Failures

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On January 9, 2023, the Federal Trade Commission (“FTC”) finalized an order with Drizly, LLC, an online marketplace for alcohol delivery services, and its Chief Executive Officer (“CEO”), James Cory Rellas over alleged...more

Farella Braun + Martel LLP

Cybersecurity Regulation: Key Takeaways From an Unusual FTC Order That Will Follow CEO for a Decade

The FTC recently issued a proposed order that would settle an enforcement action against Drizly, LLC and its co-founder and CEO, James Rellas, arising from data breaches in 2018 and 2020 that affected over 2.5 million...more

Kramer Levin Naftalis & Frankel LLP

Proposed FTC Order Targets Drizly and Its CEO for Allegedly Lax Information Security Standards Following Data Breach

On Oct. 24, the Federal Trade Commission (FTC) issued a proposed decision and order against Drizly LLC and its CEO regarding allegations that the company’s security failures led to a data breach exposing the personal...more

Alston & Bird

Recent FTC Order Has Implications for Executive Liability and Corporate Data Minimization Practices

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On October 24, 2022, the Federal Trade Commission (“FTC”) announced a proposed consent order against both Drizly LLC, an online marketplace for alcohol delivery, and its CEO over the company’s alleged security failures that...more

Alston & Bird

NYDFS Announces Significant Cybersecurity Settlement with EyeMed Vision Care

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On October 18, 2022, EyeMed Vision Care LLC (“EyeMed”) entered into a Consent Order with the New York Department of Financial Services (“DFS”) relating to a cybersecurity event from 2020 that exposed consumer nonpublic...more

Wyrick Robbins Yates & Ponton LLP

Buyers Beware: the FTC’s Case Against CafePress Highlights Privacy and Data Security Risks in Corporate Transactions

Last week the Federal Trade Commission announced a privacy and data security enforcement action against the online retail platform CafePress. The allegations in the FTC’s complaint read like a list of worst practices,...more

Jackson Lewis P.C.

FTC Settles Privacy and Security Allegations with Online Merchant for $500K and Agreement to Extensive Compliance Program

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The FTC recently settled its enforcement action involving data privacy and security allegations against an online seller of customized merchandise. In addition to agreeing to pay $500,000, the online merchant consented to...more

Alston & Bird

NYDFS Announces Cybersecurity Settlement, Addresses Multi-Factor Authentication Rules

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On April 14, 2021, the New York Department of Financial Services (“NYDFS”) announced a settlement with National Securities Corporation (“National Securities”), a licensed insurer, in connection with claims under the NYDFS...more

Robinson+Cole Data Privacy + Security Insider

NYDFS Settles with National Securities Corp. for $3M for Violations of DFS Cybersecurity Regulations

The New York Department of Financial Services (NYDFS) has settled alleged violations of the Department’s strict cybersecurity regulations with National Securities Corp. (NSC) for $3 million, over four separate cybersecurity...more

BCLP

Lessons Learned from New York’s Second Cybersecurity Action

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The New York Department of Financial Services (NYDFS) has announced its second regulatory enforcement action against a regulated entity (a New York licensed mortgage banker and loan servicer) for violating NYDFS’s...more

Goodwin

NYDFS Consent Order Signals Regulator’s Growing Focus On Financial Institutions’ Incident Response And Security Practices

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In early March, the New York State Department of Financial Services (“NYDFS”) announced a consent order that required Maine-based mortgage servicer Residential Mortgage Services, Inc. (“Residential”) to pay a $1.5 million...more

Robinson+Cole Data Privacy + Security Insider

Capital One Settles with Bank Regulator for $80M for Data Breach

The U.S. Office of the Comptroller of the Currency (OCC) announced this week that it has entered into a Consent Order and fined Capital One $80 million for the data breach the company experienced last year....more

ArentFox Schiff

Interactive Council Newsletter: Privacy Report: Airline Sues Software Provider Over Data Breach

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Delta Sues Software Provider Over Data Breach - Delta Airlines sued its customer service chat provider, [24]7.ai Inc., in New York federal court accusing it of lax digital security practices that allowed a hacker to steal...more

Sunstein LLP

Twenty Years Under the Microscope: A Small Business, a Data Breach and the FTC

Sunstein LLP on

James Grago has a nice business going. He runs a website called ClixSense.com that permits users to earn money by completing surveys and watching advertisements. Revenues grew from $6.7 million in 2015 to $9.1 million in...more

WilmerHale

New FTC Data Security Order Shows Trend in Increased Accountability for Data Security Post-Order

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On June 12, 2019 Lightyear Dealer Technologies LLC, a company that provides data storage for many of the nation’s largest auto dealers, stipulated to an Order with the Federal Trade Commission (FTC) resulting from a 2016 data...more

Fenwick & West LLP

FTC Toughening Stance on Data Security – Five Key Takeaways from Recent Consent Orders

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The Federal Trade Commission is putting more teeth into the multiyear compliance obligations of consent orders it enters into with companies to settle enforcement actions related to data breaches. The FTC recently issued a...more

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