Equifax and Facebook Settlements Overshadow More Routine FTC Summer Settlements

In addition to the sizable settlement with Equifax announced this week and the reported Facebook settlement, the FTC has issued three more typical settlement orders this summer addressing privacy and data security issues. “After two years of workshops and enforcement dormancy, the FTC appears to be back in the data protection business,” Cooley partner Travis LeBlanc observed. With insights from LeBlanc and Venable partner Ariel Wolf, this article provides an update on FTC’s summer settlements – both large and small. In addition to Equifax, we review and discuss lessons learned from the FTC’s recent settlements with a rewards website, a hardware device manufacturer and an auto dealer software and services provider. We will cover the Equifax and Facebook cases in more detail in subsequent issues as well. 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).

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