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FTC Proposes Significant Amendments to the COPPA Rule

Our Consumer Protection/FTC and Privacy, Cyber & Data Strategy teams review how the Federal Trade Commission’s proposal to amend the COPPA Rule would to create significant operational changes for website operators....more

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 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

Limit Your Health Data Sharing and Call Me in the Morning: FTC Prescribes Enforcement of the Health Breach Notification Rule for...

Our Privacy, Cyber & Data Strategy and Consumer Protection/FTC Teams analyze the FTC’s first-ever enforcement of its Health Breach Notification Rule and how the FTC is scrutinizing how companies share consumers’ online health...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

CFPB and FTC Looking to Ramp Up Data Security Requirements

Enhancing data security programs to protect personal information is a critical area companies cannot ignore. Our Privacy, Cyber & Data Strategy and Financial Services & Products groups unpack the latest moves by the Consumer...more

Hefty FTC Penalty Against Twitter Reveals Privacy Policy Disclaimers Not Sufficient

The Federal Trade Commission has levied a negotiated $150 million civil penalty against Twitter for violating an existing FTC order for alleged misrepresentations to its users, claiming the company deceptively collected...more

FTC Brings Enforcement Action for App’s Collection of Children’s Personal Data in Violation of COPPA

Our Privacy, Cyber & Data Strategy and Consumer Protection/FTC teams offer key takeaways from the Federal Trade Commission’s enforcement action in the midst of renewed emphasis on children’s privacy by both the Biden...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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