November 2012

It can be easy in the data privacy and security sphere to focus significantly on best practices, changing statutes, new administrative investigations, and evolving industry standards.  It is important, however, not to lose the forest for the trees by ignoring larger issues like “what criteria should we use to determine whether information is in fact

Regulators increasingly want to know what companies are telling consumers about how the companies are using information about their consumers.  Companies that do not properly explain how they collect, store, and use their customers’ information are facing increased scrutiny.  Nowhere is this increased scrutiny move evident than in the $22.5 million civil penalty that the