A New Norm: Prescriptive FTC Settlement With InfoTrax Addresses Reasonable Security Measures

The FTC’s proposed settlement with InfoTrax Systems, L.C., a back-end operations systems provider, contains specific requirements that can serve as guidance for companies on reasonable security measures and the supervision of third parties. The complaint alleges FTC Act violations based on InfoTrax’s failure to maintain reasonable security measures for a client company, marking the Commission’s continued enforcement under its unfairness authority. We analyze the proposed settlement and its compliance and enforcement lessons, with insight from legal experts, including an FTC spokesperson who confirmed that the stricter requirements in this settlement represent the new normal for FTC enforcement actions. See “How Facebook’s $5-Billion FTC Settlement Is Shaping Compliance Expectations” (Aug. 7, 2019).

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