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FTC Settles Enforcement Actions Concerning Protection of Social Security Numbers

Yesterday, the Federal Trade Commission (FTC) announced two proposed settlements of complaints filed against Ceridian Corporation and Lookout Services, Inc.   Both proposed consent orders require the companies to implement security measures similar to other such settlements, including development and implementation of more robust information security programs, along with biennial security assessments and reporting by qualified…
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Why Protecting “Non-Sensitive” Information Is A Sensitive Subject.

A recent data breach demonstrates some relevant concerns.  Last week a large marketing firm announced that numerous email addresses and possibly names and addresses of customers of some of its large clients (including banks) were compromised.  Some might say email addresses: “No big deal.”  Certainly, in and of themselves, email addresses probably don’t qualify as…
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Have You Really Thought About the Practices You Preach?

Your Privacy Policy Could Have Serious Legal Implications How many times have you seen website terms of use or privacy policies saying something to the effect, “We use industry standard best-practice technology to guarantee your sensitive financial transactions are 100% safe and secure?” When you publish these types of statements, you potentially expose your business…
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New Federal Law Prohibits “Data Passes” and “Negative Option” Marketing

New Laws Place Restrictions and Limits on After Sale Data Passes and Negative Option Marketing On December 29, 2010, President Obama signed the “Restore Online Shoppers’ Confidence Act” into law. This new law places restrictions and limits on after sale “data passes” and “negative option” marketing through Internet sales.   Senator John D. (Jay) Rockfeller, IV…
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