Takeaways From Former FTC Officials on the Commission’s 2019 Enforcement: General, Financial and Children’s Privacy

The FTC’s inclusion of new privacy obligations in its settlement order with Facebook was one of the most important enforcement developments in 2019, Baker Botts partner Maureen Ohlhausen, a former FTC Commissioner, told the Cybersecurity Law Report. Facebook was not the only notable case – the FTC’s 2019 Privacy and Data Security Update indicates that enforcement from the Commission continued unabated throughout the year. This first article in our two-part series includes lessons and themes from Ohlhausen and other former FTC officials on general, financial and children’s privacy enforcement. Part two will contain their guidance on data security and predictions on the FTC’s future enforcement, including commentary on the FTC’s recently issued guidance on combatting scams related to COVID-19. 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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