Earlier this month, two key regulatory bodies summed up their current perspective on organizations’ responsibility for data security and privacy. Companies that are dealing in any way with electronic consumer data and its hard to imagine any being completely disconnected from the connected world ought to be listening more closely to the regulators. Yet experience suggests not enough are. Continuing to not respond to regulators’ concerns and to not stay abreast of consumer expectations about data-handling practices could very well result in less business flexibility and more business risk given the current environment.
The first was the U.S. Federal Trade Commission. On Feb. 1, it released a staff report entitled Mobile Privacy Disclosures: Building Trust Through Transparency. If any doubt existed that the FTC no longer considers viable the "check-the-box" privacy model that some still follow, the FTC put that to bed. It observed that now "the commission’s approach to privacy and data security generally [is that] a paper exercise alone such as having written policies and procedures in the back of a file drawer or empty contractual provisions does not sufficiently uphold the privacy and security of users’ information." The report goes on to make several suggestions that underscore the breadth of the potential impact to privacy practices its changed approach may bring.
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