Privacy Promises Made Don’t Change

James Chiodo, Certified Information Privacy Professional CIPP/US

When one company buys or merges with another company, there’s typically a considerable amount of conversation taking place about how to blend differing procedures, products, policies and management.

However, an FTC letter from the Bureau of Consumer Protection to the executives at Facebook and WhatsApp should be a strong reminder for business owners both on and off the Internet. Your promises and commitments made in your privacy statement to customers do not change without the consent of a consumer.

“The Federal Trade Commission has made it very clear, that without the affirmative express consent by a consumer, a company cannot use data in a manner that is materially inconsistent with promises made at the time the data was collected. And by using such data, could subject a company to enforcement action under FTC Section 5 “Unfair Practice.”

Every company should review its privacy policies and statements regularly.


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