<div dir="ltr"><div><div dir="ltr" class="gmail_signature" data-smartmail="gmail_signature"><div dir="ltr"><div><div dir="ltr"><div dir="ltr"><div><div dir="ltr"><div dir="ltr"><div dir="ltr"><div dir="ltr"><div dir="ltr"><div dir="ltr"><div dir="ltr"><div dir="ltr"><div dir="ltr"><div dir="ltr"><div dir="ltr"><div dir="ltr"><div dir="ltr"><div><div><div dir="ltr"><div><div dir="ltr"><div><div dir="ltr"><p><a href="https://news.bloomberglaw.com/privacy-and-data-security/the-long-path-to-protecting-consumer-data-ftc-rules-explained">https://news.bloomberglaw.com/privacy-and-data-security/the-long-path-to-protecting-consumer-data-ftc-rules-explained</a><br></p><p>The Federal Trade Commission follows a longer, more complex
rulemaking process than other federal agencies, constraining its ability
to hold tech companies responsible for securing and protecting consumer
data. </p><p>But with more breaches exposing consumer data, and no federal privacy law, some commissioners are showing a <a href="https://news.bloomberglaw.com/privacy-and-data-security/ftc-signals-willingness-to-write-privacy-rules-without-congress">willingness</a> to use this approach—which could take years—to write new national data protection rules.</p><p>Companies
such as video-conferencing platform Zoom Video Communications Inc. and
period-tracking app Flo Health Inc. have come under FTC scrutiny for
misleading consumers about how secure or private their data is kept.
Others, including Twitter Inc. and Facebook Inc., could <a href="https://news.bloomberglaw.com/tech-and-telecom-law/twitter-hack-may-bring-fine-for-possible-ftc-accord-violation-1">face</a> fines after accounts were hacked and user data was <a href="https://news.bloomberglaw.com/privacy-and-data-security/facebook-data-dump-likely-to-bring-regulatory-scrutiny-lawsuits">leaked</a>.</p><h2>1. How does the FTC write rules?</h2><p>The commission must follow
what’s known as a Magnuson-Moss process for writing rules on data
protection, unless Congress specifies otherwise. This elaborate process
was created by Congress in the 1975 Magnuson-Moss Warranty-Federal Trade
Commission Improvement Act, and made more complex in 1980 revisions. It
came in response to criticism that the FTC had overreached its
authority by trying to restrict television ads promoting sugary foods to
children.</p><p>Instead of proposing a rule and giving interest groups
and the public a chance to weigh in—the standard procedure—Magnuson-Moss
requires the FTC to give Congress a heads up before a rulemaking, hold a
hearing with experts who speak to each side of an issue, and keep more
detailed records of meetings with outside groups.</p><p>Not all of the
FTC’s work is subject to Magnuson-Moss. Some laws, such as the
Children’s Online Privacy Protection Act, grant the commission authority
to follow regular rulemaking steps. Armed with such examples, the FTC
has <a href="https://www.ftc.gov/system/files/documents/reports/reports-response-senate-appropriations-committee-report-116-111-ftcs-use-its-authorities-resources/p065404reportprivacydatasecurity.pdf">called</a>
on Congress to also let it write data protection rules using a process
with fewer hurdles that would let it keep pace with changes in
technology.</p><p> </p><h2>2. What has been the result? </h2><p>Rules written under the more
complicated process take longer to complete. Before Magnuson-Moss, the
FTC issued trade regulations in about three years, on average, according
to a 2015 academic <a href="https://www.gwlr.org/wp-content/uploads/2016/01/83-Geo-Wash-L-Rev-1979.pdf">paper</a>. After the procedures were established, it took six years, on average, to issue a rule, the paper found.</p><p>Because
the process is slow and cumbersome, the FTC has used it only seven
times, the paper found. That includes to give consumers the right to a
free copy of their eyeglasses prescription after an eye exam under the
1978 <a href="https://www.ftc.gov/enforcement/rules/rulemaking-regulatory-reform-proceedings/eyeglass-rule">Eyeglass Rule</a>, the first Magnuson-Moss rule.</p><p>No
new rulemakings have been initiated under the process since 1980,
though the agency has finished work on rules that were already in
progress and amended others.</p><h2>3. How does the FTC oversee data protection now? </h2><p>The
commission has been using its authority under Section 5 of the FTC Act
to protect consumers from unfair or deceptive business practices that
involve their data, chiefly through settlements with companies that,
over time, help set precedents for what constitutes sound data
protection.</p><p>That approach has amounted to dozens of <a href="https://www.ftc.gov/enforcement/cases-proceedings/terms/245">cases</a> involving privacy and security enforcement over the past two decades.</p><p>In one prominent case, Equifax Inc., the consumer credit-rating company, <a href="https://news.bloomberglaw.com/privacy-and-data-security/equifax-agrees-to-pay-700-million-to-settle-u-s-breach-probe">agreed </a>to
pay up to $700 million and improve its data security to resolve
investigations into a 2017 hack that compromised information on more
than 140 million people.</p><p>Facebook, meanwhile, <a href="https://news.bloomberglaw.com/privacy-and-data-security/facebook-to-pay-record-5-billion-to-settle-ftc-privacy-claims">reached</a>
a record $5 billion settlement with the FTC in 2019 after a data
privacy scandal involving political consultancy Cambridge Analytica.
That settlement also gave the social media giant’s board of directors
greater responsibility for protecting user data.</p><p> </p><h2>4. What’s wrong with the current approach?</h2><p>Although the FTC
could continue with case-by-case enforcement while Congress considers
giving the agency more authority for data protection rulemaking, critics
say its settlements lack teeth as the agency can’t generally fine a
company for a first misstep.</p><p>The FTC can only issue fines for
violating an existing agreement with the agency, as in Facebook’s case,
or for issues such as children’s privacy, where a law has given the
agency penalty authority. FTC fines are further limited by a U.S.
Supreme Court ruling that <a href="https://news.bloomberglaw.com/us-law-week/supreme-court-slashes-ftc-power-to-seek-monetary-awards">slashed</a> the commission’s authority to seek monetary awards in court.</p><p>The
FTC has also faced pushback for laying out what detractors say are
vague steps for improving a company’s data security or privacy
practices.</p><p>One settlement<strong> </strong>involving LabMD Inc.
was thrown out by a federal appeals court that deemed it unenforceable
for mandating a data security overhaul without explaining what that
would involve. In wake of that ruling, the agency began directing
companies to implement <a href="https://news.bloomberglaw.com/privacy-and-data-security/ftc-takes-tougher-data-security-stance-after-labmd-fight">specific</a> data security practices.</p><h2>5. Would a new rule really protect consumer data?</h2><p>A
new FTC data protection rule, especially one written with industry
input, could ultimately better protect consumers by clearly laying out
what’s expected from data handlers, arguably easing their path to
compliance.</p><p>New regulatory boundaries could also shift the burden
for data protection away from the courts if a stronger, more transparent
FTC standard means fewer class action lawsuits filed on behalf of
consumers whose data has been compromised.</p></div></div></div></div></div></div></div></div></div></div></div></div></div></div></div></div></div></div></div></div></div></div></div></div></div></div></div></div>