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Daily Dashboard | The Blind Men, the Elephant and the FTC’s Data Security Standards Related reading: A view from Brussels: EDPS sends signal on data transfers 

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Like a group of blind men encountering an elephant—one touching the trunk and thinking “snake,” another feeling a tusk and thinking “sword,” a third caressing an ear and thinking “sail”—so do commentators, lawyers and industry players struggle to identify what “reasonable data security” practices mean in the eyes of the Federal Trade Commission (FTC). In the absence of federal legislation or regulatory guidance, the reasonableness standard is assessed on a case-by-case basis through a string of FTC enforcement actions, 47 so far, by which the agency provides the public with glimpses into its regulatory interpretation. Luckily, Westin Research Fellow Patricia Bailin, CIPP/US, has pieced together the most comprehensive view to date of the FTC’s reasonable data security standards. Now it is available as a pdf that is easy to distribute and use as a tool in your organization. IAPP VP of Research and Education Omer Tene breaks down how this tool can help you navigate the uncertainty of “reasonable security.”
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