The Commission enforces against deceptive privacy representations and unfair security practices. Remedies include consent orders with multi-year compliance obligations, monetary relief in some contexts, and injunctive terms.
Consent orders bind for twenty years in many cases.
Alternative Names:
FTC Privacy Enforcement|Section 5 Action
Why it Matters?
Consent order terms create obligations extending far beyond the underlying conduct, frequently requiring biennial assessments and executive certifications for twenty years, which makes settlement terms more consequential than any monetary component. Deception theories rest on the organization's own privacy representations, which means overstated policy language creates the exposure. Reviewing published statements against actual practice is direct risk mitigation.
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What makes consent orders consequential?
What creates deception exposure?
