When the Federal Trade Commission, in conjunction with the White House, promulgated its Consumer Privacy Bill of Rights in February 2012, one of the more intriguing considerations was that the FTC appeared to be setting up a matrix by which a company’s voluntary decision to adopt that matrix could become the basis for an FTC enforcement action. Now, after several months, it should be back at the forefront of data security considerations for U.S. businesses.
Earlier this summer, the FTC used that matrix in authorizing a federal action against Wyndham Worldwide Corp. and three of its subsidiaries – a development that highlights a possible change in stance from FTC Commissioner J. Thomas Rosch and illustrates for businesses the importance of developing detailed data/privacy policies.
Click on the PDF link above to view the full alert.