Lessons From FTC's 2018 Privacy and Data Security Update: Enforcement Takeaways

The FTC’s Privacy and Data Security Update: 2018 (Update), released on March 15, 2019, demonstrates the agency’s role in privacy and data security advocacy and enforcement continued unabated last year. In this first part of our article series covering lessons to be learned from the Update, we examine 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. Subsequent coverage will explore lessons from financial privacy and COPPA enforcement, workshops and reports, and what to expect from the agency in 2019. 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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