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Steering Clear of FTC Enforcement Actions: Rules for the Road Where the Road has Few Rules

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December 2018

By: Arthur S. Gaus

DRI - In-House Defense Quarterly - Fall 2018

The large-scale collection of customer data and the use of that data to improve service or understanding of a company's customers is de riguer in today's commercial environment. Business of all kinds collect and compile enormous troves of transaction and demographic data as a matter of course.  But recently, the data collection and retention practices of internet titans have been in the news, and not always for good reasons.  Two major developments in data-collection and retention have produced most of the headlines: the implementation of the General Data Protection Regulation (GDPR) in Europe and the ongoing fallout from the Facebook's data collection and retention practices.  Taken together, these two developments demonstrate that data collection and retention practices are drawing-and will continue to draw-increased scrutiny from both governments and consumers on both sides of the Atlantic.  For the full article click here

Arthur Gaus is an Employment attorney with Burnham Brown's employment practice group.  Mr. Gaus represents businesses in labor and employment and Americans with Disabilities Act litigation and provides practical employment advice.  He is also certified CIPP/US in American private-sector privacy law by the International Association of Privacy Professionals.

December 2018

By: Arthur S. Gaus

DRI - In-House Defense Quarterly - Fall 2018

The large-scale collection of customer data and the use of that data to improve service or understanding of a company's customers is de riguer in today's commercial environment. Business of all kinds collect and compile enormous troves of transaction and demographic data as a matter of course.  But recently, the data collection and retention practices of internet titans have been in the news, and not always for good reasons.  Two major developments in data-collection and retention have produced most of the headlines: the implementation of the General Data Protection Regulation (GDPR) in Europe and the ongoing fallout from the Facebook's data collection and retention practices.  Taken together, these two developments demonstrate that data collection and retention practices are drawing-and will continue to draw-increased scrutiny from both governments and consumers on both sides of the Atlantic.  For the full article click here

Arthur Gaus is an Employment attorney with Burnham Brown's employment practice group.  Mr. Gaus represents businesses in labor and employment and Americans with Disabilities Act litigation and provides practical employment advice.  He is also certified CIPP/US in American private-sector privacy law by the International Association of Privacy Professionals.