Consumer Data Practices: What Hospitality Companies Can Learn From the Facebook - FTC Settlement
The Federal Trade Commission's settlement with Facebook - as well as those with Twitter and Google - strongly signals that that the FTC will use its broad authority regarding "unfair and deceptive trade practices" to police the privacy beat.
Our friends at the Data Privacy Monitor put together a pretty good summary of the FTC's complaint against, and settlement with, Facebook. This should be required reading for those wanting to see how the FTC applies its standards. But those looking to familiarize themselves with what the standards are should check out the blog post from FTC staff attorney Leslie Fair - Lessons from the Facebook Settlement (even if you are not Facebook). We summarize her "practical pointers" as follows:
- Like any other advertising claim, what you say about how you handle people's data has to be truthful. That means your statements (or promises) should be backed up with substance.