Lessons From FTC 2018 Privacy and Data Security Update: Financial Privacy, COPPA and International Enforcement

In its most recent Privacy and Security Update (Update), the FTC recapped its 2018 enforcement actions, workshops and other guidance, providing information on best privacy and data security measures for companies. In this second installment of our article series on the Update, legal experts distill valuable lessons from enforcement in financial privacy and COPPA cases, and discuss the agency’s international focus. The final article in the series will explore takeaways from hearings and reports and forecast what to expect in 2019. In part one, we examined enforcement highlights from general privacy and data security cases and what these actions tell us about steps companies can take to comply with applicable laws and steer clear of the FTC’s reach. See also “Lessons and Trends From FTC’s 2017 Privacy and Data Security Update: Enforcement Actions (Part One of Two)” (Jan. 31, 2018); Part Two (Feb. 14, 2018).

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