User Beware: Data Breaches Involving Peer-to-Peer Networks May Result in FTC Enforcement Action

October 2012Articles Banking & Financial Services Policy Report

Data breaches seem to be in the headlines practically every day. Small companies, large companies, family businesses and global corporations all seem to be in the news for significant data breaches. Customers and the public have noticed these events. And, perhaps more importantly, Washington has taken notice.

This past summer, the Federal Trade Commission flexed its enforcement muscle and initiated an action regarding alleged data breaches that involved the use of peer-to-peer, or P2P, networks. This FTC action, which resulted in a proposed consent decree, demonstrates that the FTC is watching and unafraid to take action. The lesson is, at first blush, deceptively simple: all institutions need to carefully consider their data security policies and ensure compliance with them. The Devil, as it is so many times, is in the details.

View entire article (pdf)