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We Help Small, and Mid-Size Employers (SMEs) Manage Compliance with the FTC Safeguards Rule and Respond to FTC Complaints
The U.S. Federal Trade Commission (FTC) is one of a handful of agencies that share primary responsibility for protecting consumers’ privacy at the federal level. The FTC’s Safeguards Rule applies to a broad range of companies, and even when a company is not subject to the Safeguards Rule, its failure to adequately protect consumer data can still lead to agency scrutiny. To avoid FTC scrutiny—and to withstand FTC scrutiny when necessary—companies need to ensure that they have adequate data privacy and security protocols in place.
We represent small and mid-size employers (SMEs) in all FTC matters involving data privacy and security. This includes helping covered employers comply with the Safeguards Rule as well as defending employers during FTC investigations and enforcement proceedings. If you have questions or concerns about your company’s obligations or need counsel to engage with the FTC on your company’s behalf, we can help, and we encourage you to contact us to learn more.
FTC Data Privacy and Security Compliance
The FTC’s Safeguards Rule is broad in its application. While the Rule applies specifically to “financial institutions,” as the FTC notes, “the Rule defines ‘financial institution’ in a way that’s broader than how people may use that phrase in conversation.” As a result, many companies that would not normally classify themselves as financial institutions are subject to the Rule’s data privacy and security requirements.
If your company is subject to the FTC’s Safeguards Rule, we can help you implement all necessary policies, protocols, and applications. We provide custom-tailored data privacy and security documentation, and advice focused on each of our clients’ specific obligations and risks. In addition to FTC compliance, we assist with all other areas of state and federal data security compliance as well.
FTC Complaint Defense
Various data privacy and security issues can trigger FTC complaints. The FTC has published extensive guidance for employers, and it expects employers to follow this guidance when developing and implementing their data privacy and security protocols. If a complaint suggests that a company is not doing what is necessary, this can lead to swift and aggressive enforcement action from the FTC.
Along with helping companies proactively manage data privacy and security compliance, we represent companies in FTC enforcement matters. When facing FTC investigations related to alleged data privacy and security failures, companies must be very careful to avoid exposing themselves unnecessarily.
During investigations, we deal with the FTC on behalf of our clients, and we work to steer our clients’ inquiries toward efficient, favorable, and confidential resolutions. When investigations lead to litigation, we rely on our extensive experience in the area of federal data privacy and security compliance to build and execute effective defense strategies. In all FTC matters, we focus on protecting our clients as cost-effectively as possible while striving to ensure that our clients can maintain favorable relationships with the FTC going forward. Contact us for help today.