The New York Times reported earlier this week on the wholesale transfers of consumer data in the context of corporate mergers, acquisitions and bankruptcy transactions. In this report for Privacy Tracker, IAPP Westin Research Fellow Arielle Brown, CIPP/US, looks at the report and the “all-encompassing privacy policy” in the context of Section 5 of the FTC Act. “Through its enforcement actions, the FTC has made clear that altering a privacy policy in a way that is inconsistent with promises made at the time information was collected can constitute an unfair practice under Section 5 of the FTC Act,” she writes. (IAPP member login required.)
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