March 19, 2012
Partner Alysa Z. Hutnik was quoted in the article, "Attorneys Offer Tips for Avoiding FTC Privacy Investigations and Responding to Inquiries," which appeared in the Bloomberg BNA Privacy and Security Law Report. The article reviews the March 9th International Association of Privacy Professionals Global Privacy Summit. Ms. Hutnik spoke at the event, in a panel discussing what specific steps companies can take to avoid privacy investigations by the Federal Trade Commission. These steps include ensuring they adopt privacy-by-design principles and ensuring that they live up to privacy and security promises made to consumers.
In addition to listing five "privacy triggers" to avoid, Ms. Hutnik commented that companies need to address their privacy programs in "a thoughtful, comprehensive way instead of as an afterthought."
Ms. Hunik also noted that a company should ensure that privacy protections are built-in and request a meeting with staff to discuss a case, if one is filed. She said, "Don't be shy about making remedial changes during the investigation."