Say “Cooling-Off Rule” and most people (OK, most people over a certain age) think of the classic door-to-door salesman — although the scope of the Rule is broader than that. After listening to comments about the future of the Cooling-Off Rule, the FTC has decided to keep it in place, but is asking for your feedback about one important proposed change.
It’s not often we describe something as a drop-what-you’re-doing development. But if you’ve been following proposed changes to the Children's Online Privacy Protection Act (COPPA) Rule, this may qualify. After national workshops, Federal Register Notices, and hundreds of comments from the public, the FTC just issued final changes to the COPPA Rule.
Until recently, most consumers — and a whole lot of businesses — were unfamiliar with the operations of the data broker industry. Data brokers collect personal information from a variety of public and non-public sources and resell it to other companies. No doubt, there are economic benefits to the flow of certain kinds of information. But legislators, law enforcers, and others have raised concerns about the privacy implications of what goes on behind the scenes.
Usually we lay out the facts of a case and then summarize what we see as the take-away tips for business. But this time we’re switching things up. Here are the two bottom-line messages from the FTC’s ongoing action against The Cuban Exchange: It’s a Bad Idea to use robocalls to impersonate familiar groups in an effort to trick people into turning over their bank account info and other sensitive data. And it’s a Really Bad Idea when the group you impersonate is the Federal Trade Co