As the cloud security and privacy worlds come together here at the IAPP Privacy Academy and CSA Congress, the IAPP releases today a significant new study from the Westin Research Center on the “reasonable” components of a privacy and data security program as interpreted from more than 40 Federal Trade Commission (FTC) enforcement actions. Part of the IAPP’s ongoing FTC Casebook project, this report by Westin Fellow Patricia Bailin is meant to help shed light on what an acceptable level of privacy and data security could be, even as companies litigate the issue with the FTC in federal courts.
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