Skip to main content

Stick with Security: Make sure your service providers implement reasonable security measures

Thomas B. Pahl, Acting Director, FTC Bureau of Consumer Protection
Trust, but verify. That’s good advice in many contexts, including in your approach to businesses you hire to process sensitive data in your possession. Even if a breach ultimately traces back to a service provider’s conduct, from the perspective of a customer or employee whose personal information has been comprised, the buck stops with you. That’s why Start with Security cautions companies to make sure their service providers implement...

Fraud alerts vs. credit freezes: FTC FAQs

Lesley Fair
UPDATE: As of September 21, 2018, the law says credit freezes are free for everyone, and alerts now last one year (not 90 days). Read more here . Consumers are apprehensive about the security of their personal information and recent headlines about data breaches have moved the needle substantially on the -ometer that measures such things. As a business executive, your customers and employees may be coming to you with questions. Here are answers...

How an “invention promotion” outfit demoted the truth

Lesley Fair
It sounds like there was some “inventing” going on at Florida-based invention promotion firm World Patent Marketing, but a Preliminary Injunction in a case brought by the FTC suggests it wasn’t the kind that unsuspecting consumers bargained for when they forked over millions of dollars based on the defendants’ misleading promises about patenting and promoting their products. For FTC watchers, the opinion is a page-turner from start to finish. We...

Stick with Security: Apply sound security practices when developing new products

Thomas B. Pahl, Acting Director, FTC Bureau of Consumer Protection
Your company has a killer concept for an innovative app or a connected product and you’re in that initial blue-sky-and-whiteboard stage. You’ll have lots of opportunities to develop your distribution chain, create eye-catching ads, and start the social media buzz. But there’s one task that can’t wait. Now is the time to start with security – and that includes applying sound security practices when developing new products . Tech experts will tell...

Three FTC actions of interest to influencers

Lesley Fair
If you have any influence over influencers, alert them to three developments, including the FTC’s first law enforcement action against individual online influencers for their role in misleading practices. According to the FTC, Trevor Martin and Thomas Cassell – known on their YouTube channels as TmarTn and Syndicate – deceptively endorsed the online gambling site CSGO Lotto without disclosing that they owned the company. Law enforcement Counter...

Lessons from FTC’s Lenovo case: Pay attention to the man in the middle

Lesley Fair
The Wizard of Oz was right: “Pay no attention to the man behind the curtain.” That’s because according to an FTC settlement , computer company Lenovo should have been paying attention to the “man in the middle.” In this case, the “man in the middle” was preloaded ad-injecting software that put consumers’ personal information at risk from harmful man-in-the-middle attacks. When people first browsed a shopping site with their new Lenovo computers...

Stick with Security: Secure remote access to your network

Thomas B. Pahl, Acting Director, FTC Bureau of Consumer Protection
Ask a business person where their office is located and the likely answer is “everywhere.” They’re working from home, staying in the loop while traveling, and catching up on email between sales calls. For productivity’s sake, many companies give their employees – and perhaps clients or service providers – remote access to their networks. Are you taking steps to ensure those outside entryways into your systems are sensibly defended? If your...

Getting in Sync with HSR Timing Considerations

Premerger Notification Office Staff, Bureau of Competition
The Hart Scott Rodino (HSR) Act and Rules require that parties to certain mergers and acquisitions submit premerger notification filings and wait before consummating the transaction. Parties must often balance the HSR filing requirement with a number of other regulatory requirements, as well as any conditions to closing. When planning an acquisition or merger, practitioners should pay attention to the specific timing parameters in the HSR Act, 15...

4 Gramm-Leach-Bliley tips to take from FTC’s TaxSlayer case

Lesley Fair
If you or your clients are in the tax preparation field, there are three letters you should focus on. OK, I-R-S may be the first thing on your mind. But as the FTC’s proposed settlement with TaxSlayer suggests, don’t forget those other important letters: G-L-B. Under the Gramm-Leach-Bliley Act, “financial institutions” – more on what that means in a moment – must comply with the Privacy Rule and the Safeguards Rule . The Privacy Rule requires...

Stick with Security: Segment your network and monitor who’s trying to get in and out

Thomas B. Pahl, Acting Director, FTC Bureau of Consumer Protection
Who’s coming in and what’s going out? Businesses that want to stick with security build commonsense monitoring into their brick-and-mortar operations. Whether it’s a key card reader at the door or a burglar alarm activated at night, careful companies keep an eye on entrances and exits. Your computer systems deserve the same kind of watchful attention, which is why Start with Security advises you to segment your network and monitor who’s trying to...