Data Security Best Practices Derived from FTC § 5 Enforcement Actions
Topic: Antitrust and Consumer Protection
By Kurt Wimmer, a Partner with Covington & Burling LLP in its Washington, DC office, where he chairs the Data Privacy and Cybersecurity Practice, and Ashden Fein, Catlin M. Meade, and Andrew Vaden, Associates with the firm. Foreword by David A. Heiner, Vice President and Deputy General Counsel of the Regulatory Affairs team at Microsoft Corporation.
Working Paper, January 2017, 30 pages
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With the Federal Trade Commission treating its growing roster of consent decrees entered into with businesses accused of “unfair trade practices” related to data breaches, regulatory targets must be cognizant of certain standards that can be derived from these settlements.