October 22, 2021

Volume XI, Number 295

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From the Data Protection and Privacy Conference: Words of Advice from the Federal Trade Commission

Kevin Moriarty from the Division of Privacy and Identity Protection of the Federal Trade Commission addressed the privacy conference on Wednesday.  His discussion focused on the current FTC policy work, including workshops and privacy roundtables.  Kevin reviewed historical cases brought under Section 5 of the FTC Act, and ended with words of advice to prevent your organization from becoming a target of an FTC enforcement action.  He suggests you:

  1. Review the FTC website and use the Consumer Protection Resources. (Kevin said the FTC looks favorably on organizations that can show they have reviewed the site and used the resources provided.)
  2. Keep your promises; do what your privacy policy says you do.
  3. Share information only for permissible purposes.
  4. Dispose of information properly –don’t forget about paper!
  5. Keep up with common threats such as stolen credentials, SQL injection attacks, and access to Wi-Fi networks.
  6. Develop an incident response plan before you have an incident.

Amy Malone is attending the Data Protection & Privacy Law Conference in Arlington, Virginia this week and will be providing updates.

©1994-2021 Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C. All Rights Reserved.National Law Review, Volume II, Number 205
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About this Author

The frictionless flow of information is a defining feature of today’s information economy. Your organization’s ability to transfer customer data, employee files, financial records, and other information around the country or the globe quickly and cheaply has opened a world of new opportunities. Privacy laws vary by jurisdiction and are interpreted unpredictably, and even if your business is extremely conscientious, it can make a false step as it captures, uses, transfers, and discloses personal information. The consequences can be serious and even devastating — heavy...

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