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Comp Blog

FTC oversight of data security

By: Danielle Wright

CommentTuesday - July 22, 2014

As you may know, the Federal Trade Commission has broad authority to intervene in many matters related to consumer finance. In recent years, the FTC has made several moves into the rapidly growing market for mobile applications, especially when it comes to the collection of private personal data.

The FTC recently cracked down on a number of companies for failing to invest time and resources into securing customer data that was attained or transmitted through mobile applications. In its suit against the Wyndham hotel company, the FTC alleged that Wyndham had been too lax in its oversight of its customer payment information, which was breached on three separate occasions.  Under its “unfair and deceptive” statutory enforcement authority the FTC has also targeted companies for failing to comply with their own written data security policies.

Since legal and compliance costs from an FTC action can be very costly for smaller institutions like credit unions, make sure to review your data collection policies/practices to ensure that-

  • Consumer data is collected efficiently, transparently, and with notice to the consumer
  • Data is anonymized and periodically wiped to minimize exposure to a potential security breach
  • Strict standards and disclosures are in place when providing this data to third parties
  • Both your customers and your servers use complex user id’s and passwords
  • Highly sensitive data, such as payment card info, is encrypted
  • Servers are actively monitored and updated for security patches
  • All of your partners and subsidiaries have proper policies/procedures before connecting them to your main network


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