Posts in FTC Consent Decrees

affirmative express consent, Do Not Track, Gateway, material change, retroactive, twitter

Twitter's New Tailored Suggestion Service Raises Questions

By InfoLawGroup LLP on June 05, 2012

The buzz words in privacy over the last few months (really longer than that) have been "Do Not Track." Twitter is just the latest company to adopt the DNT browser option, indicating in a blast email to all Twitter users that the setting is now available for implementation if a user so chooses. Interestingly, however, a much less publicized setting was also presented in that same email blast: Twitter's new "tailored suggestion feature." Applications and widgets created by Twitter will begin to collect data about Twitter users from third party websites that feature those products. This is an entirely new feature from Twitter, and is being implemented as a default option for both new and existing Twitter users.

IAPP, International Association of Privacy Professionals, Red Flags Rule

Live from the IAPP Global Privacy Summit in Washington, DC, It's Monday Afternoon

By InfoLawGroup LLP on April 19, 2010

This week, I will be providing short updates from the IAPP Global Privacy Summit in Washington, DC. The conference will be in full swing tomorrow, and I will report on various panels and topics of interest. In the meantime, as I prepare to see old and new friends at the Welcome Reception this evening, a few thoughts on what I expect to see and hear a lot over the next few days.

Dave & Buster's, FTC, hacker, information security program, personal information

Dave & Buster's Busted: Another Allleged Failure to Implement "Reasonable Security"

By InfoLawGroup LLP on March 26, 2010

We are seeing more and more private litigation and regulatory enforcement actions around the issue of what constitutes "reasonable security." This week we see another. Once again the FTC asserts that a company has failed to take "reasonable and appropriate security measures" to protect personal information. Yesterday, in its 27th case challenging inadequate data security practices by organizations that handle sensitive consumer information, the FTC announced settlement of its complaint against Dave & Buster's, the restaurant chain. The FTC alleged in its complaint that, from April 30, 2007 to August 28, 2007, a hacker exploited vulnerabilities in Dave & Buster's systems to install unauthorized software and access approximately 130,000 credit and debit cards.