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Federal Trade Commission issues new and expansive guidance on data breach notification

The Federal Trade Commission has issued new guidance explicitly stating it now interprets the Federal Trade Commission Act as imposing consumer data breach notification obligations. Notably, unlike state data breach notification laws already in effect, the guidance does not specify particular data points that would trigger a notification obligation if compromised. Rather, the guidance imposes notification obligations when a compromise of any data would “increase the likelihood that affected parties will suffer harm.” Read more…