Our Privacy, Cyber & Data Strategy Team highlights the shift in priorities for privacy and cybersecurity regulation and enforcement across U.S. agencies under the second Trump Administration....more
Our Consumer Protection/FTC and Privacy, Cyber & Data Strategy teams unpack Starwood Hotels’ and Marriott International’s settlements with the Federal Trade Commission and Marriott’s settlement with state attorneys general...more
10/21/2024
/ Civil Monetary Penalty ,
Cybersecurity ,
Data Breach ,
Data Security ,
Federal Trade Commission (FTC) ,
Incident Response Plans ,
Liability ,
Marriott ,
Personal Information ,
Popular ,
Regulatory Authority ,
Risk Assessment ,
Settlement
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
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
On October 31, 2022, the Federal Trade Commission (FTC) announced it has taken action against education technology provider Chegg Inc. (“Chegg”) for its “careless” cybersecurity practices that exposed sensitive personal...more
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
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
As the healthcare and financial impacts of COVID-19 continue to evolve with the global pandemic, the use of AI technology and associated risks have received greater attention. On April 8, 2020, the FTC posted an extensive...more
Our Privacy & Data Security Group reviews the Eleventh Circuit’s decision narrowing the FTC’s authority to impose broad cybersecurity measures on defendants, but cautions it would be a mistake to interpret the ruling as...more