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ARTICLE · 21 JUNE 2019

Don't Misrepresent Your U.S. – E.U. Privacy Shield Status: FTC Brings An Enforcement Action

Here, the FTC used its authority under Section 5 of the FTC Act to compel ReadyTech to withdraw representations that it was "in the process of certifying" that they comply with the Privacy Shield

United StatesPrivacy

As US companies continue to spend time and effort complying and responding to all of the new privacy laws and regulations both in the United States and aboard (i.e. GDPR and California Consumer Privacy Act of 2018) companies cannot forget the basics. If you represent something in your Privacy Policy it better be accurate, up to date, and not misleading!

On July 2, 2018, the Federal Trade Commission (FTC) issued a number of press releases and a proposed settlement with California-based employee training company ReadyTech Corporation. In announcing the settlement, FTC Chairman Joe Simons said, "Today's settlement demonstrates the FTC's continuing commitment to vigorous enforcement of the Privacy Shield." According to the FTC, this is the 4th case enforcing the Privacy Shield and 47th case enforcing international privacy frameworks such as the Safe Harbor framework and the Asia Pacific Economic Cooperation Cross Border Privacy Rules.

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