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One of the biggest takeaways from Judge Esther Salas’ recent opinion in FTC v. Wyndham Worldwide Corp., et al was that in the absence of formal Federal Trade Commission (FTC) rules on data security practices, companies should consider the settlements and advisory opinions from prior FTC enforcement actions for guidance. Accordingly, we have compiled a list of three major practices cited in recent data security enforcement actions, along with the best practices that companies should consider implementing.

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