On October 27, 2023, the FTC approved an amendment to the Safeguards Rule (the “Amendment”) requiring that non-banking financial institutions notify the FTC in the event of a defined “Notification Event” where customer information of 500 or more individuals was subject to unauthorized acquisition. The Amendment becomes effective 180 days after publication in the […]
About Kathleen Benway
FTC Launches Investigation into Creator of ChatGPT
In mid-July, the Federal Trade Commission (FTC) reportedly opened an investigation into OpenAI, the maker of ChatGPT, sending the company an extensive Civil Investigative Demand (CID). While FTC investigations are normally non-public, the Washington Post published what appears to be part of the CID sent from the FTC to OpenAI. This investigation comes on the […]
FTC Seeks Comments on a New Verifiable Parental Consent Mechanism Under COPPA
On July 19, 2023, the Federal Trade Commission (the “FTC”) announced that it is seeking comment on an application for a new verifiable parental consent mechanism under the Children’s Online Privacy Protection Act (“COPPA”). The application, submitted jointly by the Entertainment Software Rating Board, Yoti, and SuperAwesome (collectively, the “Applicants”), requests the FTC to approve […]
HHS and FTC Fire a Warning Shot at Healthcare Companies Using Online Tracking Technologies
On July 20, 2023, the Office for Civil Rights (“OCR”) of the U.S. Department of Health and Human Services (“HHS”), and the Federal Trade Commission (“FTC”) published a joint letter sent to approximately 130 hospital systems and telehealth providers. The FTC/OCR letter warns that certain online tracking technologies that “may be present” on the recipients’ […]
FTC Delays Effective Date of Certain Changes to the Safeguard Rule
On November 15, 2022, the Federal Trade Commission (FTC) announced that it is delaying the effective date of certain changes to the Gramm–Leach–Bliley Safeguards Rule. The Safeguards Rule, which first became operative in 2003, imposes certain security requirements on non-banking financial institutions. The FTC amended the Rule in December 2021, and several provisions under the […]