Executive Summary Today, the Court of Justice of the European Union (‘CJEU’) handed down its long-awaited judgment in the ‘Schrems 2.0’ case (Facebook Ireland and Schrems (Case C-311/18)), about the validity of two means of legitimizing transfers of personal data outside the EEA under the EU General Data Protection Regulation (‘GDPR’)[1]. In somewhat of a […]
Consumer Protection/FTC
The FTC Expands its FCRA Enforcement Activity In Action Against Retailer
Most businesses are already familiar with the Fair Credit Reporting Act (“FCRA”) and the various requirements to protect the fairness, accuracy, and privacy of consumer credit information. However, a recent FTC enforcement action against the retailer Kohl’s Department Store, Inc. (“Kohl’s”) has brought a rarely used provision of the statute to light. This provision—codified […]