Analysis of the FTC Final Staff Report on Privacy
On March 26, 2012, the FTC released its final Staff Report titled, “Protecting Consumer Privacy in an Era of Rapid Change,” which proposes a three-part privacy framework that would apply to online and offline commercial entities that collect and use certain types of consumer data. While the FTC was careful to state its proposals are only intended to provide a framework for congressional legislation, they are good indications of what the FTC considers acceptable privacy practices. There are numerous items and recommendations in the report that, if implemented, could have a significant effect on many different types of businesses. Our detailed analysis of the Report and its potential implications for businesses is available here.