From Fox Rothschild’s Privacy Compliance & Data Security blog
The Federal Trade Commission (FTC) has offered tips for data protection during the COVID-19 crisis.
- Consider privacy and security as you’re developing your products and services, and not after launch. Although we will be flexible and reasonable when it comes to bringing enforcement actions against companies engaged in good faith, thoughtful efforts to address the effects of the pandemic, it doesn’t pay to be in the news for privacy and security problems.
- Use privacy protective technologies, eg decentralized protocols that allow users to voluntarily share encrypted data directly with epidemiologists.
- Consider using anonymous, aggregate data. For example, if a consumer has granted you permission to use their location data, you may disclose a heat map of average distances traveled for public health purposes without needing consent.
- Delete data when the crisis is over. If you tell consumers you’re collecting, analyzing, using, or sharing information for emergency public health purposes, only use it for those purposes, and delete the data when the need is over.