Regulation of Companies' Data Security Practices under the Federal Trade Commission Act and California Unfair Competition Law

摘要

With the FTC and the California Attorney General declaring it a priority to pursue data security enforcement actions, companies can expect to see more enforcement actions in the near future. Companies should take a proactive approach and assess whether their data security practices are reasonable and appropriate given their unique circumstances. Companies should make use of the resources provided by the FTC and the California Attorney General's office to assist them in protecting themselves against costly regulatory and private actions.