A Look at Recent Federal Trade Commission and Consumer Financial Protection Bureau Initiatives Concerning Privacy and Data Security
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Our discussion examines the FTC\\u2019s Advanced Notice of Proposed Rulemaking relating to what it describes as \\u201ccommercial surveillance\\u201d and the CFPB\\u2019s circular confirming that covered persons and service providers may violate the Consumer Financial Protection Act\\u2019s prohibition against unfair acts or practices when they fail to adequately safeguard consumer information.\\xa0 We consider the ANPR\\u2019s scope, its areas of focus, and potential federal and state obstacles to the FTC\\u2019s initiative. After providing an overview of the CFPB\\u2019s circular, we look at the data security measures highlighted by the CFPB, the CFPB\\u2019s authority to address data security, precedents to which companies can look in assessing the adequacy of their data security measures and potential exposure, and steps to mitigate risk.
Alan Kaplinsky, Ballard Spahr Senior Counsel, hosts the conversation, joined by Greg Szewczyk, Co-Leader of the firm\\u2019s Privacy and Data Security Group, and Tim Dickens, an associate in the firm\\u2019s Litigation Department focusing on privacy and data security.
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