Libby Greismann

Latest Articles

In a new report, the Federal Trade Commission (FTC) declines to call for new laws but makes clear that it will continue to use its existing tools it to aggressively police unfair, deceptive—or otherwise illegal—uses of big data. Businesses that conduct big data analytics, or that use the results of such analysis, should familiarize themselves with the report to help ensure that their practices do not raise issues. The report, titled “Big Data: A Tool…
In a new report, the Federal Trade Commission (FTC) declines to call for new laws but makes clear that it will continue to use its existing tools it to aggressively police unfair, deceptive—or otherwise illegal—uses of big data. Businesses that conduct big data analytics, or that use the results of such analysis, should familiarize themselves with the report to help ensure that their practices do not raise issues. The report, titled “Big Data: A Tool…
Last week was a big one for California’s privacy regime. In a landmark move, Governor Jerry Brown signed into law four bills further protecting Californians’ privacy rights: Three strengthen the state’s data breach notification statute and impose restrictions on operators of automated license plate recognition systems (ALPRs), and one requires law enforcement to obtain a warrant for the collection of digital records and location. A.B. 964, S.B. 570 and S.B. 34 California passed the nation’s…
The FTC has released its much anticipated report on the Internet of Things (“IoT”) – a topic that has been top-of-mind for many companies. The FTC’s report, “Internet of Things: Privacy & Security in a Connected World” (the “Report”), discusses the benefits and risks associated with IoT, and addresses the privacy and data security measures the FTC recommends for consumer-facing IoT products and services [The FTC’s discussion of IoT within the report, consistent with the…
President Obama provided a preview of his State of the Union address next week which will propose comprehensive data privacy legislation, including a nationwide data-breach notification law, a Consumer Privacy Bill of Rights, and limitations on the use of student data. The announcement comes at a pivotal time for privacy in the wake of the high-profile data breaches that filled the news in 2014. In his remarks, President Obama called for Congress to create a…
Snapchat’s recent settlement with the Federal Trade Commission (FTC) generally provides a comprehensive but not groundbreaking roadmap to the FTC’s privacy and data security expectations in the mobile environment under Section 5 of the FTC Act, with two very notable exceptions: It now appears that companies are required to follow researchers’ blogs and other writings to see if there are any privacy or data security vulnerabilities, and to act on any such information promptly; and…
Snapchat’s recent settlement with the Federal Trade Commission (FTC) generally provides a comprehensive but not groundbreaking roadmap to the FTC’s privacy and data security expectations in the mobile environment under Section 5 of the FTC Act, with two very notable exceptions: It now appears that companies are required to follow researchers’ blogs and other writings to see if there are any privacy or data security vulnerabilities, and to act on any such information promptly; and…
The SEC plans to examine the cybersecurity practices of over 50 registered broker-dealers and investment advisers. The SEC announced its plan in an April 15, 2014 Risk Alert, which closely follows the March 26 Cybersecurity Roundtable at which Chair Mary Jo White underscored the importance of cybersecurity to market security and customer data protection. At the Roundtable, Chair White emphasized the “compelling need for stronger partnerships between the government and private sector” to address cyber…