Proskauer on Privacy

Tag Archives: consent order

FTC-Google Settlement Marks Two “Firsts” in FTC Privacy Enforcement

Google recently settled charges by the Federal Trade Commission (FTC) that Google's social networking service, Buzz, violated the FTC Act. The FTC-Google settlement prohibits Google from misrepresenting the extent to which it maintains and protects the confidentiality of users' information and from misrepresenting its compliance with the US-EU Safe Harbor Framework. In that regard, the settlement represents two important "firsts" in FTC enforcement. … Continue Reading

Federal Trade Commission Announces Settlement with TJX Over Inadequate Security Practices

According to a proposed settlement announced by the Federal Trade Commission (“FTC”) on March 27, 2008, discount retailer TJX will be required to implement a comprehensive information security program to remedy deficiencies in protecting sensitive consumer information. If approved, the settlement will resolve allegations that the company engaged in practices that failed to provide reasonable and … Continue Reading

FTC Sets Sights on Goal: Student Lender Taken to School for Data Security Breakdowns

On March 4 the FTC announced that a consent agreement has been reached in its 17th case challenging data security practices by a company handling sensitive consumer information. Goal Financial, LLC, a San Diego-based student loan company, has agreed to implement a comprehensive information security program, avoid future misrepresentations about its data security practices, and receive independent, third-party audits of its data security program every two years for the next 10 years. The consent order does not provide for a civil fine. … Continue Reading
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