On October 30, 2017, Sears Holding Management Corporation (“Sears”) petitioned the Federal Trade Commission (“FTC”) to reopen and modify the settlement to which they agreed in 2009. At that time, Sears agreed to a consent order to resolve the FTC’s complaint that Sears allegedly did not adequately disclose the scope of its collection of “online … Continue Reading
The oracle of Silicon Valley, Mary Meeker – a partner at Kleiner Perkins – just published her highly anticipated 2015 Internet Trends Report. Meeker’s report is the ultimate compilation of essential technology statistics, and is one of the most widely read and respected insights into the future of the Internet and technology trends. Encompassing everything … Continue Reading
In December, 23 privacy authorities – many of which are members of the Global Privacy Enforcement Network (GPEN) – signed an open letter to the operators of seven app marketplaces, urging them to improve consumers’ access to privacy information on mobile apps. The letter states that: Mobile apps that collect data in and through mobile … Continue Reading
In May this year, members of the Global Privacy Enforcement Network (GPEN) conducted a privacy sweep of 1,200+ mobile apps. The findings are now available (here). GPEN is an informal network of 27 Data Protection Authorities (“DPAs”) established in 2007. Its members include the UK’s ICO, Australia’s OAIC, and Canada’s OPC. DPAs from 26 jurisdictions … Continue Reading
This post was written by Judith L. Harris and Rob Jackson. The U.S. District Court for the Southern District of Florida recently released a decision in a TCPA suit brought by a man seeking damages in connection with a series of autodialed telephone calls made to his mobile phone. In his decision on cross motions … Continue Reading
This post was also written by Frederick Lah. On February 1, the FTC released its Mobile Privacy Disclosures Guidance (the Guidance) setting forth best practice recommendations for platforms, app developers, third parties such as ad networks and analytics companies, and app trade associations. We previously wrote about the Guidance when it was issued. On February 15, Assistant … Continue Reading
Today, the Federal Trade Commission released detailed guidance on privacy in the mobile environment – at the same time it announced its largest-ever settlement with an app developer for alleged privacy violations. Combined with aggressive action on mobile privacy issues by the California attorney general’s office, Mobile Privacy Disclosures provides every company associated with a … Continue Reading
This post was also written by Amy S. Mushahwar and Frederick Lah. On August 21, Jumptap and Evidon announced a partnership to create and implement the AdChoices icon in mobile web and mobile app advertisements. Evidon, one of the earliest providers of privacy solutions that comply with the Digital Advertising Alliance (“DAA”) Self-Regulatory Program for … Continue Reading
This post was written by Amy S. Mushahwar. On July 11, the National Institute of Standards and Technology (“NIST”) released Guidelines for Managing and Securing Mobile Devices in The Enterprise, its draft policy for securing mobile devices that will supplement its already-published general security recommendations for any IT technology. In these draft Guidelines, which are a … Continue Reading
This post was also written by Frederick Lah. In early June, New Jersey Attorney General Jeffrey Chiesa and the New Jersey Division of Consumer Affairs brought a complaint against California-based mobile app developer 24×7 Digital LLC for alleged violations of the Children’s Online Privacy Protection Act (“COPPA”). The state alleged that 24×7 Digital, through its … Continue Reading
This post was written by Cynthia O’Donoghue. The French Data Protection Authority (the “CNIL”) issued a press release 19 April 2012 detailing its planned enforcement agenda for the coming year. The CNIL announced that it intends to conduct around 450 on-site inspections during 2012, with particular focus on six specific themes. The CNIL will also … Continue Reading
This post was written by Cynthia O’Donoghue. In the midst of a rapid increase in the availability and accuracy of facial recognition technology in recent years, the Article 29 Working Party adopted in March this year Opinion 02/2012, highlighting the data protection considerations on the use of facial recognition technology in services such as social … Continue Reading
This post was also written by Christopher G. Cwalina, Amy S. Mushahwar and Frederick Lah. This week, the Federal Trade Commission (FTC) released its long-awaited final Commission Consumer Privacy Report, entitled “Protecting Consumer Privacy in an Era of Rapid Change” (“Final Report”). The FTC emphasizes that the report only sets forth industry best practices and was “not intended” to … Continue Reading
On 27 February 2012, with the support of Europe’s largest mobile operators, the GSMA published a set of global Privacy Design Guidelines for Mobile Application Development. These guidelines come just days after the largest US based App providers, including Google, Apple and Amazon, agreed to legally enforceable privacy standards. The Mobile App Privacy Design Guidelines … Continue Reading
This post was also written by Christopher G. Cwalina, Khurram Nasir Gore, Amy S. Mushahwar and Steven B. Roosa. A warning from the California Attorney General’s office to mobile app developers: “Don’t get cute!” On February 22, California’s Attorney General Kamala Harris announced that her office and the six leading mobile application platform providers – Amazon, … Continue Reading
This post was written by Amy S. Mushahwar. Today, in response to the controversy surrounding cellphone tracking software from Carrier IQ, U.S. Representative Edward Markey (D-MA) released a draft of a cellphone privacy bill. As background, the Carrier IQ software first made headlines in November, when a researcher posted a YouTube video claiming to show … Continue Reading
And, Adds a Third Arena in the Senate for Privacy Discussions This post was also written by Chris Cwalina, Amy Mushahwar & Mike Sacks. On Monday, Senator Jay Rockefeller (D-WV) introduced a bill entitled, “Do-Not-Track Online Act of 2011,” that will kick off a dialogue over how and in what circumstances companies should be allowed to … Continue Reading
This post was also written by Amy Mushahwar. Bill Adds to the Web of Proposed Privacy Legislation and Contains Much More Than Kids Do Not Track Today, Rep. Ed Markey (D-Mass.) circulated a discussion draft of his kids online do-not-track bill, co-sponsored by Joe Barton (R-Tex.) that proposes to make it illegal to use kids’ … Continue Reading
