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Kathleen Benway

FTC Seeks Comments on a New Verifiable Parental Consent Mechanism Under COPPA

July 24, 2023 By Kathleen Benway, Maki DePalo and Hyun Jai Oh

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 […]

Filed Under: Adtech & Digital Tracking, Consumer Protection/FTC, Privacy & Cyber Regulatory Enforcement, Privacy & Cybersecurity Litigation Tagged With: Children's Online Privacy Protection Act (COPPA), Federal Trade Commission (FTC)

HHS and FTC Fire a Warning Shot at Healthcare Companies Using Online Tracking Technologies

July 20, 2023 By Kathleen Benway, Daniel Felz and Sara Pullen

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’ […]

Filed Under: Adtech & Digital Tracking, Board Governance & Cyber Risk Management, Consumer Protection/FTC, HIPAA/Health Information Privacy, Security & Breach Response, Privacy & Cyber Regulatory Enforcement

FTC Delays Effective Date of Certain Changes to the Safeguard Rule

November 17, 2022 By Kathleen Benway and Hyun Jai Oh

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 […]

Filed Under: Board Governance & Cyber Risk Management, Consumer Protection/FTC, Uncategorized Tagged With: Data Protection, Federal Trade Commission (FTC)

Update: FTC Amendments to the Safeguards Rule and Request for Comment on Proposed Reporting Requirement Published to the Federal Register

December 15, 2021 By Kim Peretti, Kathleen Benway and Kristen Bartolotta

As an update to prior coverage of the FTC’s final revisions to the Gramm-Leach-Bliley Safeguards Rule (Final Rule), following its publication in the Federal Register on December 9, 2021, the Final Rule now will take effect on January 8, 2022, 30 days after publication in the Federal Register. Revisions to the Final Rule include an […]

Filed Under: Board Governance & Cyber Risk Management, Privacy & Cyber Regulatory Enforcement

FTC Revises the Safeguards Rule and Proposes Mandatory Reporting of Cybersecurity Events

November 1, 2021 By Kathleen Benway and Kim Peretti

On October 27, 2021, the FTC released its much-anticipated final revisions to the Gramm-Leach-Bliley Safeguards Rule (Safeguards Rule or Final Rule), following a 3-2 vote along party lines and also released a notice of proposed rulemaking that would  require reporting to the FTC of certain cybersecurity events. Revisions to the Safeguards Rule Effective since 2003, […]

Filed Under: Board Governance & Cyber Risk Management, Consumer Protection/FTC, Privacy & Cyber Regulatory Enforcement

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