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Consumer Protection/FTC

FTC Publishes Amendments to COPPA Rule

April 22, 2025 By Maki DePalo and Hyun Jai Oh

On April 22, 2025, the Federal Trade Commission (FTC) published the finalized amendments (Amendments) to the Children’s Online Privacy Protection Rule (COPPA Rule) that would impose additional restrictions on website and online service operators that collect personal information from children under the age of thirteen. The Amendments will become effective on June 23, 2025.  Operators […]

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

To Delete or Not to Delete: Can 23andMe Really Sell Genetic Data Via Bankruptcy?

April 7, 2025 By Daniel Felz, Joyce Gresko, William Sugden, Kennedy Bodnarek, Anna von Spakovsky and Sara Pullen

On March 23, 2025, 23andMe Holding Co. (“23andMe”) filed for bankruptcy in the Eastern District of Missouri, potentially setting in motion the sale of genetic data collected from more than 15 million people.  This has led to news outlets and state Attorneys General encouraging consumers to delete their 23andMe data before it is sold as […]

Filed Under: Consumer Protection/FTC, HIPAA/Health Information Privacy, Security & Breach Response, Privacy & Cyber Regulatory Enforcement

FTC Finalizes COPPA Rule Amendments

January 17, 2025 By Maki DePalo and Hyun Jai Oh

On January 16, 2025, the Federal Trade Commission (FTC) voted 5-0 to approve the finalized amendments to the Children’s Online Privacy Protection Rule (COPPA Rule) that would offer additional privacy safeguards for children under the age of thirteen. The amened COPPA Rule will require operators to obtain separate verifiable parental consent before disclosing personal information […]

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

Data Breach Notification Requirements under the Safeguards Rule Now in Effect

June 11, 2024 By Daniel Felz and Dorian Simmons

For years, the Gramm-Leach-Bliley Act (GLBA) has required financial institutions to maintain reasonable safeguards for consumer data, but has only had limited breach-reporting requirements. To the extent financial institutions were subject to breach-reporting obligations, these were set by non-GLBA legislation, such as state law, or by relatively narrow incident-reporting rules under Interagency Guidelines overseen by […]

Filed Under: Board Governance & Cyber Risk Management, Consumer Protection/FTC, Crisis & Data Breach Response, Privacy & Cyber Regulatory Enforcement, Privacy & Cybersecurity Litigation

FTC Denies an Application to Add a New Verifiable Parental Consent Mechanism Under COPPA Rule Without Prejudice

April 2, 2024 By Maki DePalo and Hyun Jai Oh

On March 29, 2024, the Federal Trade Commission (the “FTC”) published a unanimous decision to deny an application by the Entertainment Software Rating Board, Yoti, and SuperAwesome (collectively, the “Applicants”) to add a new verifiable parental consent (“VPC”) mechanism under the Children’s Online Privacy Protection Rule (“COPPA Rule”). The application, which our previous blog post […]

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

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