FTC Refutes Wyndham’s Challenge; Unreasonable Security Is “Unfair”

Patricia Ballin reports:

Generating a flurry of conversation among privacy professionals worldwide, the U.S. Federal Trade Commission (FTC) last week filed its response to Wyndham Worldwide Corporation’s interlocutory appeal in the Third Circuit.


The FTC’s response outlines and affirmatively answers the three questions presented in Wyndham’s appeal: whether a company’s unreasonable failure to protect the security of consumer data constitutes an unfair act or practice; whether Wyndham had constitutionally sufficient notice that it needed to take reasonable steps to protect the consumer data entrusted to it, and whether the complaint sufficiently alleged that the data breaches caused consumers substantial injury that they could not have reasonably avoided.

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