As expected, the Federal Communications Commission (FCC) has handed down sweeping new privacy and security rules for Internet service providers (ISPs). On Thursday, October 27, 2016, a sharply divided commission voted to enact these new
Continue Reading FCC Orders Far-Reaching New Privacy and Data Security Rules
On June 22, 2016, the Federal Trade Commission (FTC) announced that it has settled charges that InMobi, a Singapore-based mobile advertising company, deceptively tracked the locations of hundreds of millions of consumers, including children, to
Continue Reading WSGR Alert: FTC Brings First Privacy Enforcement Action Against a Mobile Ad Network
The Consumer Financial Protection Bureau (CFPB) recently brought its first data security enforcement action, adding itself to the growing list of federal regulators tackling data security issues. The CFPB’s enforcement action was against Dwolla Inc., a Des Moines, Iowa-based online payment platform. The CFPB alleged that Dwolla misrepresented its data security practices, and as a result, Dwolla agreed to pay a $100,000 penalty and to implement significant data security measures.1 While this is only its first data security-related action, the CFPB appears to be taking very seriously its role in securing consumers’ financial information. The requirements the agency placed on Dwolla’s board of directors make this clear, as the board will be held accountable for any security shortcoming by the company. This goes beyond the typical requirements imposed by the Federal Trade Commission (FTC), the regulator with the most extensive data security experience, in its data security enforcement actions. As such, companies, especially financial technology start-ups, should take note of the data security requirements placed on Dwolla by the CFPB, and ensure that any statements made regarding the security of consumers’ information are accurate.
Continue Reading CFPB Brings First Data Security Enforcement Action
On February 23, 2016, the Federal Trade Commission (FTC) announced a settlement with computer hardware maker ASUSTeK Computer, Inc. (ASUS). The ASUS settlement highlights the FTC’s position regarding security in the connected device market: connected
Continue Reading WSGR Alert: FTC Settles with Manufacturer of Home Network Routers over Alleged Data Security Flaws
The Federal Trade Commission (FTC) recently approved a new method for website operators and mobile application developers (“operators”) to obtain parental consent to collect personal information from children.1 Under this new method, which is the first to use biometric identifiers to verify that a parent is providing consent for a child, the FTC will permit operators to use facial recognition technology to compare an image of the person providing consent with an image of verified photo identification, such as a drivers’ license or passport. If the two images match, the user is verified and can provide consent for the child to use the website or mobile application.
Continue Reading FTC Approves Facial Recognition as Method of Obtaining Parental Consent to Collect Children’s Information
On September 9, 2015, the Federal Trade Commission (FTC) held its first “Start with Security” conference at the University of California Hastings College of the Law in San Francisco. The conference was the first in a series of events hosted by the agency intended to provide additional guidance to businesses regarding how to keep consumers’ information secure.
The FTC’s San Francisco event was aimed primarily at start-ups and software developers, with panels focusing on building a culture of security, scaling security during periods of rapid growth, investing in security, vulnerability disclosure and response, and implementing security features. The panels were each moderated by a staff attorney from the FTC’s Division of Privacy and Identity Protection, with panelists hailing primarily from Silicon Valley tech companies. Each panel is summarized below.
Continue Reading FTC Begins “Start with Security” Conference Series