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FTC Approves New Data Breach Notification Requirement for Nonbanking Financial Institutions

With an amendment to its Safeguards Rule, the Federal Trade Commission has joined other federal agencies regulating cybersecurity breaches. Our Privacy, Cyber & Data Strategy Team analyzes how the amendment will affect...more

FTC Approves New Data Breach Notification Requirement for Non-Banking Financial Institutions

On October 27, 2023, the FTC approved an amendment to the Safeguards Rule (the “Amendment”) requiring that non-banking financial institutions notify the FTC in the event of a defined “Notification Event” where customer...more

FTC Launches Investigation into Creator of ChatGPT

In mid-July, the Federal Trade Commission (FTC) reportedly opened an investigation into OpenAI, the maker of ChatGPT, sending the company an extensive Civil Investigative Demand (CID). While FTC investigations are normally...more

HHS and FTC Fire a Warning Shot at Healthcare Companies Using Online Tracking Technologies

On July 20, 2023, the Office for Civil Rights (“OCR”) of the U.S. Department of Health and Human Services (“HHS”), and the Federal Trade Commission (“FTC”) published a joint letter sent to approximately 130 hospital systems...more

FTC Delays Effective Date of Certain Changes to the Safeguard Rule

On November 15, 2022, the Federal Trade Commission (FTC) announced that it is delaying the effective date of certain changes to the Gramm–Leach–Bliley Safeguards Rule. The Safeguards Rule, which first became operative in...more

Update: FTC Amendments to the Safeguards Rule and Request for Comment on Proposed Reporting Requirement Published to the Federal...

As an update to prior coverage of the FTC’s final revisions to the Gramm-Leach-Bliley Safeguards Rule (Final Rule), following its publication in the Federal Register on December 9, 2021, the Final Rule now will take effect on...more

FTC Revises the Safeguards Rule and Proposes Mandatory Reporting of Cybersecurity Events

On October 27, 2021, the FTC released its much-anticipated final revisions to the Gramm-Leach-Bliley Safeguards Rule (Safeguards Rule or Final Rule), following a 3-2 vote along party lines and also released a notice of...more

High Profile Settlements, Strengthened Data Security Orders, and COPPA: The FTC’s 2019 Privacy and Data Security Update

Each year the Federal Trade Commission (the “FTC” or “Commission”) publishes a report on its activities with respect to consumer privacy and data security during the prior year.  ...more

The Updated CCPA Regulations: 30 Potentially Material Business Impacts

California Attorney General Xavier Becerra has released updated regulations to the California Consumer Privacy Act (CCPA) that contain a number of material modifications to the initial CCPA regulations released in October...more

FTC Blog Post Highlights Efforts to Strengthen Data Security Orders

The Federal Trade Commission’s Bureau of Consumer Protection director used a blog post to summarize three primary areas where the FTC has strengthened data security orders. ...more

FTC Consumer Protection Bureau Director Highlights Efforts to Strengthen Data Security Orders

On January 6, 2020, the Federal Trade Commission’s (FTC) Bureau of Consumer Protection Director Andrew Smith published a blog post summarizing the agency’s “New and improved FTC data security orders,” as part of its efforts...more

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