The FTC has demonstrated that it will not ignore activity that could negatively impact consumers, including scams tied to the recent COVID‑19 pandemic, and its 2019 Privacy and Data Security Update (Update) is evidence of its unabated enforcement efforts. This second article in our two-part series on takeaways from the Update contains guidance from former FTC officials on best data security practices, their predictions on the FTC’s future enforcement and strategies for combatting scams related to COVID‑19. Part one covered their views on best practices for general, financial and children’s privacy based on enforcement. See our three-part series on lessons from the FTC’s 2018 Privacy and Data Security Update: “Enforcement Takeaways” (Apr. 24, 2019); “Financial Privacy, COPPA and International Enforcement” (May 1, 2019); and “Hearings, Reports and 2019 Predictions” (May 8, 2019).