Data security will undoubtedly remain an enforcement priority for the Federal Trade Commission in 2023. A presentation on the FTC’s approach to data security by Deputy Chief Technologist Alex Gaynor at a Commission open meeting on December 14, 2022, highlighted four provisions found in one or more recent FTC consent orders as particularly important, though not reflecting the full array of safeguards the FTC expects organizations to employ.

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Photo of Janis Kestenbaum Janis Kestenbaum

Janis Kestenbaum is a partner in the Privacy & Security practice and Advertising, Marketing & Promotions industry group. Janis represents companies under investigation by the Federal Trade Commission (FTC), state attorneys general, congressional committees, and foreign data protection authorities regarding privacy, data security…

Janis Kestenbaum is a partner in the Privacy & Security practice and Advertising, Marketing & Promotions industry group. Janis represents companies under investigation by the Federal Trade Commission (FTC), state attorneys general, congressional committees, and foreign data protection authorities regarding privacy, data security, and consumer protection issues.

Photo of Rebecca Engrav Rebecca Engrav

Rebecca Engrav helps companies that use data solve their highest-stakes privacy, data security, and artificial intelligence/machine learning (AI/ML) challenges before government regulators and in litigation.

Photo of Aaron Haberman Aaron Haberman

Aaron Haberman is experienced in defending companies in government investigations and advising them regarding compliance with state and federal laws including the Federal Trade Commission (FTC) Act, the Controlling the Assault of Non-Solicited Pornography and Marketing (CAN-SPAM) Act, the Health Insurance Portability and…

Aaron Haberman is experienced in defending companies in government investigations and advising them regarding compliance with state and federal laws including the Federal Trade Commission (FTC) Act, the Controlling the Assault of Non-Solicited Pornography and Marketing (CAN-SPAM) Act, the Health Insurance Portability and Accountability Act (HIPAA), the Children’s Online Privacy Protection Act (COPPA), and the California Consumer Privacy Act (CCPA).

Photo of Emma Roberts Emma Roberts

Emma Roberts has assisted various clients—from Fortune 500 companies to emerging startups—with a wide range of matters at both the state and federal court level. Emma has experience providing pre-litigation counseling, managing e-discovery, engaging in pleadings and motions practice, and developing trial strategy.