Caleb Skeath and Danielle Kehl of Covington & Burling write:
In a recent blog post, the Federal Trade Commission highlighted three key changes it made in 2019 in its approach to issuing orders in data security enforcement matters. As stated by Andrew Smith, the Director of the FTC’s Bureau of Consumer Protection, in the blog post, the agency intends for these changes to strengthen consumer protections while providing companies with more specific and actionable guidance about how to improve their data security practices. However, the FTC’s shift in approach may also have an impact on how companies view risks associated with FTC enforcement, as the changes could result in additional obligations for a company and members of its senior leadership team.
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