Reed Freeman

Latest Articles

Big data is now big business. In recent years, due to the exponential growth of databases (spurred at least in part by social media and cloud storage) and of the capability of technology to undertake data analytics on a massive scale, organisations have started to appreciate the potential hidden value that could be derived from their data. Indeed, in March 2014, Neelie Kroes (Vice President of the EU Commission responsible for the Digital Agenda) reflected…
Big data is now big business. In recent years, due to the exponential growth of databases (spurred at least in part by social media and cloud storage) and of the capability of technology to undertake data analytics on a massive scale, organisations have started to appreciate the potential hidden value that could be derived from their data. Indeed, in March 2014, Neelie Kroes (Vice President of the EU Commission responsible for the Digital Agenda) reflected…
The Federal Trade Commission (FTC) announced this week that it sent warning letters to more than 60 national advertisers regarding the inadequacy of disclosures in their television and print ads. The letters are part of an initiative named “Operation Full Disclosure,” which the FTC implemented to review fine print disclosures and other disclosures that it believed were difficult to read or easy for consumers to overlook, yet included critical information that consumers would need to…
The Federal Trade Commission (FTC) announced this week that it sent warning letters to more than 60 national advertisers regarding the inadequacy of disclosures in their television and print ads. The letters are part of an initiative named “Operation Full Disclosure,” which the FTC implemented to review fine print disclosures and other disclosures that it believed were difficult to read or easy for consumers to overlook, yet included critical information that consumers would need to…
California Attorney General Kamala Harris released a long-awaited report entitled Making Your Privacy Practices Public (Report) on May 21, 2014. The Report recommends “best practices” for compliance with the California Online Privacy Protection Act (CalOPPA). It was originally intended to answer critical questions about exactly what website, online service, and mobile application operators (collectively, “site operators”) must do to comply with CalOPPA’s new do not track (DNT) disclosure obligations, which took effect on January 1,…
California Attorney General Kamala Harris released a long-awaited report entitled Making Your Privacy Practices Public (Report) on May 21, 2014. The Report recommends “best practices” for compliance with the California Online Privacy Protection Act (CalOPPA). It was originally intended to answer critical questions about exactly what website, online service, and mobile application operators (collectively, “site operators”) must do to comply with CalOPPA’s new do not track (DNT) disclosure obligations, which took effect on January 1,…
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…
In a much anticipated decision in the class action In re Hulu Privacy Litigation, U.S. Magistrate Judge Laurel Beeler of the U.S. District Court for the Northern District of California has shed new light on the meaning of “personally identifiable information” (PII) under the Video Privacy Protection Act (VPPA). This has important implications for companies that host videos on their websites and integrate their services with social media companies or web analytics service providers. The…
In a much anticipated decision in the class action In re Hulu Privacy Litigation, U.S. Magistrate Judge Laurel Beeler of the U.S. District Court for the Northern District of California has shed new light on the meaning of “personally identifiable information” (PII) under the Video Privacy Protection Act (VPPA). This has important implications for companies that host videos on their websites and integrate their services with social media companies or web analytics service providers. The…