Most companies have a privacy policy in place for the protection
of consumer data (or should), but merely adopting a reasonable
privacy policy is by itself not enough. Rather, a company
must also actively ensure compliance with the policy it adopts.
Though there can be hesitation in expending resources in adopting,
implementing, maintaining and supporting a privacy policy
governing a company's consumer protection practices, such
expense pales in comparison to the amounts that may be paid to
resolve a levied Federal Trade Commission (FTC)
fine.
Consider the case of VTech, a Hong Kong based company which
sells tablets, other electronics and software as educational tools
for children. In November, 2015, VTech learned that its Learning
Lodge Navigator online platform had been compromised. The Learning
Lodge Navigator platform contained names, gender, and birthdates of
children. In total, as of the time of the breach, about 2.25
million parents registered and created
