Nov 162017
 
 November 16, 2017  Breaches, Business, Featured News, Online

Calvin Cohen writes:

The Federal Trade Commission (“FTC”) is soliciting public comments on a petition filed by Sears Holdings Management (“Sears”) to reopen and modify a 2009 FTC order regarding the tracking of personal information on their software apps.  The petition is notable for a number of reasons.  First, the Sears consent order was a seminal order in the development of the FTC’s privacy jurisdiction, standing for the proposition that a company cannot “bury” disclosures that consumers would not expect in long privacy notices.  Second, the concept of modifying 20-year consent orders is an important one in light of changes over time.  Third, the petition seeks to correct the unintended consequences that a consent order can have on future technologies when such an order regulates present ones.

Read more on Covington & Burling Inside Privacy.

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