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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.1 According to the FTC, the reason for this extraordinary step was to address additional allegations of misconduct by the ride-sharing company in connection with a data breach it suffered in 2016. The revised complaint includes new factual allegations regarding that breach,2 and the revised consent order includes significant new reporting obligations for the company regarding future breaches, new obligations for the order’s mandated privacy program, and additional reporting and recordkeeping obligations that will last for longer periods of time.3

Those that closely follow the FTC know that any modifications to consumer protection settlements after they have been proposed by the FTC are extremely rare, so it’s worth taking a closer look at what triggered this unusual action and the important new insight it provides into the FTC’s current thinking on what it considers unreasonable security practices. Additionally, the FTC’s revised complaint provides, for the first time, concrete guidance on what it considers “legitimate” uses of a bug bounty program.
Continue Reading What’s Old Is New Again: FTC Takes Rare Step of Withdrawing and Reissuing Expanded Data Security Settlement with Uber in Light of 2016 Data Breach

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 privacy and data security promises.1 Specifically, the FTC levied two deception counts against Uber: (1) that the company had failed to consistently monitor and audit internal access to consumers’ personal information, despite public promises to do so; and (2) that the company had failed to provide reasonable security for consumers’ personal information stored in its databases, despite its security promises. Under the resulting proposed consent order, Uber will be prohibited from misrepresenting how it monitors or audits internal access to consumers’ personal information and how it protects and secures that data. Uber will also be required to implement a comprehensive privacy program that will be subject to independent biennial audits for the next 20 years, and will need to comply with the standard set of consent order recordkeeping and compliance reporting and monitoring requirements.
Continue Reading Key New Takeaways from Uber’s Privacy and Data Security Settlement with the FTC