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ARTICLE · 31 MAY 2012

FTC v. Myspace Part II - The Takeaways

Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.
Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.
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Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.

Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.

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Much can be learned from how the FTC has evaluated the adequacy of Myspace’s privacy policy when compared to its actual day-to-day procedures.

United StatesMedia, Telecoms, IT, Entertainment

The FTC has again provided us with a road map to compliance through the Myspace consent order. Here are the takeaways that should concern every company with an online presence.

Keeping the FTC Out of Your Space — The Takeaways

Much can be learned from how the FTC has evaluated the adequacy of Myspace's privacy policy when compared to its actual day-to-day procedures. The most important thing to take away from the FTC Order and its allegations in the complaint is that companies must practice what they promise. Superficially complying with your privacy policy will not pass the FTC's strict standards when it comes to accurate and adequate privacy policy disclosure. Companies must evaluate how their current practices may even indirectly provide customer PII to third parties and violate the company's privacy policy. The following are a few important steps you should take to keep the FTC out of your space:

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