Last week, British Airways (BA) became one of the first public relations victims of the General Data Protection Regulation (GDPR). Per reports from TechCrunch, BA requested that individuals who had tweeted BA regarding flight delay complaints respond on Twitter—to
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A Privacy Shield Enforcement Action: More to Come?
For the fourth time, the Federal Trade Commission (FTC) has reached a consent agreement with a company for alleged misrepresentations regarding Privacy Shield certification. A California-based company, ReadyTech Corporation, agreed to a settlement whereby it is “prohibited from misrepresenting its…
California, Privacy, and the New Normal – CA AB 375 Signed Into Law
This afternoon, Governor Brown signed into law California Assembly Bill 375, the California Consumer Privacy Act of 2018. The law is unprecedented in the United States that it applies European-level compliance obligations akin to the now infamous General Data Protection Regulation (GDPR), which…
Privacy Shield: Year One Updates You Need To Know
This month we’re celebrating Privacy Shield’s first birthday (admittedly, a bit belated) with an update on everything Privacy Shield. There have been a number of developments on the Privacy Shield-front that companies certified or seeking self-certification under Privacy Shield need…
Class Action Lawsuits over Alleged COPPA Violations Reinforce Importance of Compliance
Earlier this month, three class action lawsuits were filed against companies for alleged violations of the Children’s Online Privacy Protection Act (“COPPA”). These lawsuits are raising eyebrows as COPPA does not provide for a private right of action, and a…
Data for Sale . . . at a Price – FTC Imposes $104 Million Judgment against Company over Alleged Unlawful Sharing of Consumers’ Sensitive Information
On July 5, 2017, the FTC announced a settlement with Blue Global Media, LLC (“Blue Global”) and its CEO Christopher Kay over allegations that the company solicited consumers to provide sensitive information based on false pretenses and then shared that…
Third State Adopts Biometric Privacy Law
On June 1, 2017, Washington State joined Illinois and Texas as the third state to pass a biometric privacy law. The law, H.B. 1493, which goes into effect July 23, 2017, covers any business entity that collects biometric identifiers…
Children’s Privacy: FTC Issues New COPPA Guidance for IoT and Connected Devices
Last week, the Federal Trade Commission (“FTC”) released a new report, Six-Step Compliance Plan for Your Business, to help companies understand their obligations under the Children’s Online Privacy Protection Act (“COPPA”). In addition to reviewing longstanding COPPA requirements, the…
Dish Network Hit with Damages of 280 Million and 61 Million in Two Separate Lawsuits for Long-standing Violations of Telemarketing Laws
In what is being hailed by the Federal Trade Commission as “a record-setting win for American consumers,” and what should be viewed as a cautionary tale for marketers, satellite TV provider Dish Network (“Dish”) was recently found liable for repeated…
Times They Are A-Changin’: Oregon and Illinois Bills Latest in Push by States to Regulate Internet Privacy
In the past five months, we’ve seen a significant shift in the direction of privacy regulation at the federal level. As discussed in our previous post, Congress voted (and President Trump signed) a resolution repealing last year’s FCC Order…