Category Archives: Privacy

CFPB report on carve-outs for financial institutions in state data-privacy laws

The Consumer Financial Protection Bureau has released a report examining federal and state-level privacy protections for consumers’ financial data. The report notes that protections under federal regulations for financial data have limits. Yet, many new state data privacy protections exempt financial institutions and consumer financial data covered by federal law, even though states generally have […]

Who is a “consumer” under the Video Privacy Protection Act?

Enacted in 1988, the Video Privacy Protection Act  (VPPA) makes it unlawful for a “video tape service provider” to “knowingly disclose[], to any person, personally identifiable information concerning any consumer of such provider.” The statute further defines “consumer” as “any renter, purchaser, or subscriber of goods or services from a video tape service provider.”  The […]

Busy week at the Federal Trade Commission

FTC Sends Nearly $1.9 Million in Refunds to Customers Harmed by Hey Dude’s Violations of the Mail Order Rule (8/6) FTC Action Leads to Permanent Bans for Scammers Behind Sprawling Credit Repair Pyramid Scheme (8/5) FTC Investigation Leads to Lawsuit Against TikTok and ByteDance for Flagrantly Violating Children’s Privacy Law (8/2) FTC Submits Comment to […]

Strahilevitz & Liu paper offers theory for Article III standing in data breach cases

Lior Strahilevitz of Chicago and Lisa Yao Liu of the Columbia Business School have written Cash Substitution and Deferred Consumption as Data Breach Harms. Here’s the abstract: Federal courts have long been divided over whether consumers whose data are breached suffer an “injury in fact” that gives them standing to sue under Article III of the […]

Solove & Hartzog: The Failure of Data Security Law

Daniel J. Solove of George Washington Woodrow Hartzog of Boston University and the Stanford Law School Center for Internet and Society have posted on SSRN a chapter from their book, Breached! Why Data Security Law Fails and How to Improve It. The chapter is titled The Failure of Data Security Law. Here’s the abstract: In […]

9th Cir. grants en banc review to consider personal jurisdiction over online businesses

The Ninth Circuit Court of Appeals last week granted en banc review in a case called Briskin v. Shopify, to consider whether a state may exercise specific personal jurisdiction over a defendant that unlawfully uses its nationally accessible web platform to extract data from in-state consumers. As reporter Alison Frankel of Reuters wrote, “The court’s […]

FCC fines the wireless carriers for illegally sharing customers’ location information

The Federal Communications Commission announced yesterday that it fined the nation’s largest wireless carriers for illegally sharing access to customers’ location information without consent and without taking reasonable measures to protect that information against unauthorized disclosure. Sprint and T-Mobile – which have merged since the investigation began – face fines of more than $12 million […]

FTC’s updated Health Breach Notification Rule covers app developers

The Federal Trade Commission just updated its Health Breach Notification Rule to revise definitions and clarify its coverage to include developers of health mobile apps and other technology. The rule, which requires vendors to notify affected consumers and the FTC following a data breach affecting personal health records, also requires additional information in notices to […]

WaPo reports congressional deal on consumer online privacy bill

Here (behind paywall). According to the article, the bill would preempt state privacy laws and provide for a private cause of action. The bill enjoys support from Senate Commerce Committee chair Maria Cantwell, a Democrat, and House Energy and Commerce Committee chair Cathy McMorris Rodgers, a Republican. Whether it will pass in a presidential election year […]

A CFPB proposed rule on data broker practices is on its way

For awhile now, the Consumer Financial Protection Bureau has been scrutinizing the role and responsibilities of data brokers in collecting and selling consumers’ personal data. In a message at the White House Office of Science and Technology Policy this week, CFPB Director Rohit Chopra said that a proposed rule to provide greater oversight of third-party […]