News & Analysis as of

Consent Order Data Breach Enforcement Actions

Robinson+Cole Data Privacy + Security Insider

FTC Order with GoDaddy Finalized Over Lax Data Security

On May 21, 2025, the Federal Trade Commission (FTC) finalized its order with GoDaddy over allegations that GoDaddy “failed to implement standard data security tools and practices to protect customers’ websites and data.” In a...more

Wyrick Robbins Yates & Ponton LLP

Something Old, Something New: Latest NYDFS Cybersecurity Regulation Enforcement Action Emphasizes Policy Implementation, Training,...

The New York State Department of Financial Services recently announced that it has entered into a consent order with PayPal, Inc. for violations of the NYDFS Cybersecurity Regulation. The consent order, under which PayPal has...more

Goodwin

New York Department of Financial Services Reaches $2,000,000 Settlement with Peer-to-Peer Payment Platform

Goodwin on

On January 23, 2025, the New York Department of Financial Services (DFS) announced that it reached a $2,000,000 settlement as part of a broader consent order with a peer-to-peer payment platform (“P2P”) about its...more

Goodwin

51 State Financial Regulatory Agencies Enter Settlement and Consent Order with Nonbank Mortgage Servicing Companies

Goodwin on

​​​​​​​​On January 9, 2025, 51 State Financial Regulatory Agencies (the “Agencies”) announced a coordinated consent order and settlement agreement with nonbank mor​tgage servicing companies (the “Companies”). ...more

Epiq

Minimizing Data to Minimize Exposure: Information Governance and Data Security Overlap

Epiq on

How important is it for organizations to keep track of their data footprint? The Federal Trade Commission (FTC) thinks this is crucial. On Jan. 9, 2023, the FTC finalized a consent order following a breach. The order was...more

Farella Braun + Martel LLP

Cybersecurity Regulation: Key Takeaways From an Unusual FTC Order That Will Follow CEO for a Decade

The FTC recently issued a proposed order that would settle an enforcement action against Drizly, LLC and its co-founder and CEO, James Rellas, arising from data breaches in 2018 and 2020 that affected over 2.5 million...more

Wyrick Robbins Yates & Ponton LLP

Buyers Beware: the FTC’s Case Against CafePress Highlights Privacy and Data Security Risks in Corporate Transactions

Last week the Federal Trade Commission announced a privacy and data security enforcement action against the online retail platform CafePress. The allegations in the FTC’s complaint read like a list of worst practices,...more

Robinson+Cole Data Privacy + Security Insider

NYDFS Settles with National Securities Corp. for $3M for Violations of DFS Cybersecurity Regulations

The New York Department of Financial Services (NYDFS) has settled alleged violations of the Department’s strict cybersecurity regulations with National Securities Corp. (NSC) for $3 million, over four separate cybersecurity...more

BCLP

Lessons Learned from New York’s Second Cybersecurity Action

BCLP on

The New York Department of Financial Services (NYDFS) has announced its second regulatory enforcement action against a regulated entity (a New York licensed mortgage banker and loan servicer) for violating NYDFS’s...more

Robinson+Cole Data Privacy + Security Insider

Capital One Settles with Bank Regulator for $80M for Data Breach

The U.S. Office of the Comptroller of the Currency (OCC) announced this week that it has entered into a Consent Order and fined Capital One $80 million for the data breach the company experienced last year....more

Sunstein LLP

Twenty Years Under the Microscope: A Small Business, a Data Breach and the FTC

Sunstein LLP on

James Grago has a nice business going. He runs a website called ClixSense.com that permits users to earn money by completing surveys and watching advertisements. Revenues grew from $6.7 million in 2015 to $9.1 million in...more

WilmerHale

New FTC Data Security Order Shows Trend in Increased Accountability for Data Security Post-Order

WilmerHale on

On June 12, 2019 Lightyear Dealer Technologies LLC, a company that provides data storage for many of the nation’s largest auto dealers, stipulated to an Order with the Federal Trade Commission (FTC) resulting from a 2016 data...more

Fenwick & West LLP

FTC Toughening Stance on Data Security – Five Key Takeaways from Recent Consent Orders

Fenwick & West LLP on

The Federal Trade Commission is putting more teeth into the multiyear compliance obligations of consent orders it enters into with companies to settle enforcement actions related to data breaches. The FTC recently issued a...more

Wilson Sonsini Goodrich & Rosati

What's Old Is New Again: FTC Takes Rare Step of Withdrawing and Reissuing Expanded Data Security Settlement with Uber in Light of...

On April 12, 2018, the Federal Trade Commission (FTC) announced that it was withdrawing its proposed August 2017 privacy and data security settlement with Uber Technologies and issuing a new and expanded proposed settlement....more

Shumaker, Loop & Kendrick, LLP

Client Alert: FTC Gives Guidance in Slaying the Data Breach Dragon

The FTC has recently provided specific guidance on what it considers appropriate data breach protection activity by financial institutions. Such guidance came by virtue of a proposed consent order, dated August 29, 2017,...more

Wilson Sonsini Goodrich & Rosati

Key New Takeaways from Uber’s Privacy and Data Security Settlement with the FTC

On August 15, 2017, the Federal Trade Commission (FTC) announced that it had reached an agreement with Uber Technologies to settle allegations that the ride-sharing company had deceived consumers by failing to live up to its...more

Bond Schoeneck & King PLLC

Cybersecurity and Data Privacy: CFPB Takes Unprecedented Action Against Company (3/16)

A new regulatory authority has entered the field of data security: the relatively new Consumer Financial Protection Board (CFPB). On March 2, the CFPB announced that it had reached a consent order with an Iowa-based company...more

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