Further to our report last week (see "Facebook"), Sullivan & Cromwell's memo on the FTC's data privacy breach settlement with Facebook provides a substantively robust but concise, highly instructive overview of the key aspects of the settlement Order's mandates impacting the company's board, privacy and compliance functions, and privacy practices & policies, with thoughtful takeaways for companies looking to proactively mitigate their data privacy-related risks. The settlement order is subject to district court approval.
Access additional information and resources on our Data Privacy page under Cases/Enforcement Actions. This post first appeared in the weekly Society Alert!