The Anatomy of an FTC Privacy and Data Security Consent Order

Daniel Solove and Woodrow Hartzog write:

The Federal Trade Commission (FTC) recently entered into a consent order with the media service Snapchat for not living up to its promises about how it maintains the privacy and security of user’s data. The FTC order prohibits Snapchat from “misrepresenting the extent to which it maintains the privacy, security, or confidentiality of users’ information” and requires the company “to implement a comprehensive privacy program that will be monitored by an independent privacy professional for the next 20 years.”

In a post titled Will a Government Settlement Improve Snapchat’s Privacy? Don’t Count on It, Farhad Manjoo at the New York Times slams the FTC for not being harder on Snapchat. He views FTC consent orders as imposing weak penalties and proscriptive measures, serving “mainly to add a veneer of legitimacy over whatever moves the companies planned to make anyway.”

Read their response to those who think these consent orders are just a slap on the wrist on LinkedIn.

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