Partners Alysa Hutnik
and Dana Rosenfeld
co-authored the Law360
article, "Practical Privacy Takeaways From FTC's Deal With HTC." The article discusses the FTC's recent privacy law enforcement action against HTC America Inc. The FTC alleged that the device manufacturer did not sufficiently secure the software that it developed for its smartphones and tablet computers, and did not accurately describe its data handling practice to device users.
This enforcement action is indicative that the FTC will continue to closely scrutinize companies' practices with respect to the handling and security of personal information, and will evolve just as quickly and aggressively as technology. That focus is likely to continue and remain a high priority for the Commission for the foreseeable future, and companies would be wise to allocate sufficient resources to ensure that privacy is meaningfully addressed in business practices and policies.
This article outlines the FTC's most recent "privacy by design" law enforcement action, and identifies several practical tips to keep in mind for companies that design and market products capable of collecting, storing, or disclosing personal information.