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Data Security

Welcome back. Part 1 was an overview of recent Federal Trade Commission (FTC) data security enforcement actions. This Part 2 is intended to help businesses operating outside regulated industries figure out how to interpret the “reasonable” standard in U.S. state data security enforcement and laws.

Like the FTC, state attorneys general, using their enforcement power under their states’ “mini FTC Acts” (aka consumer protection laws) have initiated enforcement actions against businesses for unfair and/or deceptive data security practices—often together with other states (e.g., Equifax Inc., Dunkin Brands, Inc., Uber Technologies). Unlike the FTC, however, state attorneys general also enforce data security laws in their respective states. In this Part 2, we review recent state enforcement actions against businesses with ‘unreasonable’ data security and also the minimum requirements in key state data security laws requiring reasonable security.

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