Our Consumer Protection/FTC and Antitrust Teams highlight a spate of activity by the Federal Trade Commission (FTC) in its final days under the leadership of Lina Khan and offers a preview of what’s to come with Andrew...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
The revamped Health Breach Notification Rule by the Federal Trade Commission (FTC) took effect on July 29, 2024, expanding consumer privacy protections to the users of online health platforms and health and wellness apps. Our...more
8/16/2024
/ Breach Notification Rule ,
Consumer Privacy Rights ,
Data Breach ,
Data Privacy ,
Data Security ,
Digital Health ,
Electronic Protected Health Information (ePHI) ,
Federal Trade Commission (FTC) ,
Health Insurance Portability and Accountability Act (HIPAA) ,
Medical Records ,
Patient Privacy Rights ,
PHI
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
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
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
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
The Federal Trade Commission has issued new guidance under which consumers or companies should be notified of data breaches “regardless of whether a breach notification law applies.” Our Consumer Protection/FTC Team analyzes...more
Our Consumer Protection/FTC Team examines what the Federal Trade Commission may prioritize now that Chair Lina Khan has her Democratic majority in place....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
The effects of the final interoperability rules from the Department of Health and Human Services will be significant for data security in the health care industry, despite enforcement delays. Our Health Care and Privacy &...more
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
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
2/14/2020
/ Attorney General ,
California Consumer Privacy Act (CCPA) ,
Consumer Privacy Rights ,
Corporate Counsel ,
Cybersecurity ,
Data Collection ,
Data Privacy ,
Data Protection ,
Data Security ,
Opt-Outs ,
Personal Information ,
Privacy Laws ,
Right to Delete
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
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