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Idea from Penny Polokoff


How to Improve the FTC Privacy & Security Consent Decrees


While the terms of FTC consent orders can appear quite detailed and privacy-protective, there is considerable evidence that consent orders “lack teeth,” permitting companies tremendous flexibility to satisfy the terms of the consent order without improving privacy and security practices internally. When the FTC has enforced the terms of its consent decree, the resulting penalties can be so miniscule as to ensure the penalties are simply the cost of doing business. In this blog post we discuss va


Penny Polokoff