Facebook’s experience with regulators is a cautionary tale.  Several European Union Data Protection Authorities formed a Contact Group to coordinate their investigations of Facebook.  The moral of this story is that when one regulator in the EU becomes interested in reviewing privacy compliance, do not become surprised if there are soon several DPA’s who coordinate on doing the same thing.  The same can often be true in the United States.  Include planning for responding to multiple regulator requests in your incident response plan.

Photo of Amy Carlson Amy Carlson

Amy Carlson is Of Counsel in the firm’s Corporate group and has more than 20 years of experience assisting clients with a wide range of privacy matters. Using her understanding of the intersection of law and technology along with her understanding of business…

Amy Carlson is Of Counsel in the firm’s Corporate group and has more than 20 years of experience assisting clients with a wide range of privacy matters. Using her understanding of the intersection of law and technology along with her understanding of business, she helps companies develop and implement privacy policies, plans and audits, as well as manage data breaches. Amy also has experience with e-commerce, intellectual property, telecommunications, security policy, international privacy and export control issues. Amy is a Certified Information Privacy Professional and a Certified Information Privacy Manager by the International Association of Privacy Professionals. She co-leads the firm’s privacy initiative.

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