FTC

FTC/FCC MOU: Even the Justice League Needs It In Writing

data security

On November 13, 2015, the Federal Trade Commission and the Federal Communications Commission entered into a Memorandum of Understanding to address coordination of consumer protection actions by each agency.  Following a wave of what observers perceive as a turf battle between the FTC and FCC (namely the reclassification of broadband internet access services as a common carrier service outside the FTC’s jurisdiction), and a dramatic increase in FCC data security regulatory enforcement actions, the MOU suggests that the FTC and FCC are in fact serious about cooperation and collaboration, especially on data security issues.  Although organizations have better transparency and predictability in the enforcement landscape, they should also anticipate more sophisticated investigations based on richer data and improved investigative techniques.

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PRIVACY POLICIES AND THE SALE OF CORPORATE ASSETS: It pays to plan ahead to preserve the value of your data assets

privacy policy

Personal data is a valuable corporate asset.  At times, the personal information collected from customers (such as email address, mailing address, phone number, etc.) can be a company’s most valuable asset.  Unfortunately, when a company attempts to sell this asset, it can find the value of the data significantly diminished due to promises made in a privacy policy the company implemented years before it ever contemplated such a sale.

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