Tag Archives: Social Media

Irish ODPC Publishes 2012 Annual Report

Posted on May 21, 2013 by Hunton & Williams LLP

On May 20, 2013, the Irish Office of the Data Protection Commissioner (“ODPC”) published its annual report for 2012 (the “Report”). The Report summarizes the activities of the ODPC during 2012, including its investigations and audits, policy matters, and European and international activities.

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Tags: Compliance, E-Privacy Directive, EU Regulation, European Union, Facebook, International, Ireland, Online Privacy, Security Breach, Social Media, Telecommunications, Twitter

SEC Clarifies Use of Social Media Under Regulation FD

Posted on April 8, 2013 by Hunton & Williams LLP

On April 2, 2013, the Securities and Exchange Commission issued a report regarding the investigation of a prominent public company and its CEO over disclosures made on the CEO’s personal social media page. The Commission did not bring enforcement charges in this case, but the report set forth the Commission’s view that, under certain circumstances, issuer-sponsored social media can be a permissible channel of dissemination of information under Regulation FD.

Adopted in 2000, Regulation FD generally prohibits public companies and personnel acting on their behalf from selectively disclosing material, nonpublic information to certain groups, such as brokers, investment advisers, analysts and shareholders who are likely to trade on information, without concurrently making widespread public disclosure.

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Tags: Financial Privacy, Online Privacy, Securities and Exchange Commission, Social Media

UK ICO Publishes Further Analysis of Commission’s Revised Data Protection Framework

Posted on March 22, 2013 by Hunton & Williams LLP

On February 12, 2013, the UK Information Commissioner’s Office published a further analysis of the European Commission’s proposed General Data Protection Regulation (the “Proposed Regulation”). This latest analysis supplements the initial analysis paper on the Proposed Regulation published on February 27, 2012. Although the general views expressed in its initial paper stand, the ICO has now provided greater detail regarding its views of the substantive provisions of the Proposed Regulation.

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Tags: Accountability, Data Controller, Data Processor, Data Transfer, Enforcement, EU Data Protection Directive, EU Regulation, European Commission, European Union, Information Commissioners Office, International, Privacy By Design, Social Media, United Kingdom

German DPAs Adopt Resolutions on Proposed U.S.–EU Free Trade Zone, Social Networks and EU Data Protection

Posted on March 20, 2013 by Hunton & Williams LLP

On March 14, 2013, the 85th Conference of the German Data Protection Commissioners concluded in Bremerhaven. This biannual conference provides a private forum for the 16 German state data protection authorities (“DPAs”) and the Federal Commissioner for Data Protection and Freedom of Information, Peter Schaar, to share their views on current issues, discuss relevant cases and adopt Resolutions aimed at harmonizing how data protection law is applied across Germany.

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Tags: Data Controller, Data Processor, Data Protection Authority, EU Data Protection Directive, EU Regulation, European Commission, European Union, Events, Germany, International, Online Privacy, Social Media

UK ICO issues Guidance on BYOD for Organizations

Posted on March 18, 2013 by Hunton & Williams LLP

On March 7, 2013, the UK Information Commissioner’s Office (“ICO”) published guidance (the “Guidance”) on Bring Your Own Device (“BYOD”) to explain to data controllers “what they need to consider when permitting the use of personal devices to process personal data for which they are responsible.” BYOD refers to the use of individuals’ personal devices to access and store corporate information.

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Tags: Accountability, BYOD, Christopher Graham, Data Controller, Data Protection Act, European Union, General, Geolocation, Information Commissioners Office, International, Personally Identifiable Information, Social Media, United Kingdom, Workplace Privacy

European Commission Launches Cybersecurity Strategy and Draft Directive on Network and Information Security

Posted on February 8, 2013 by Hunton & Williams LLP

On February 7, 2013, the European Commission, together with the High Representative of the Union for Foreign Affairs and Security Policy, launched their cybersecurity strategy for the European Union (“Strategy”). As part of this Strategy, the European Commission also proposed a draft directive on measures to ensure a common level of network and information security (“NIS”) across the EU (the “Directive”).

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Tags: Cloud Computing, Cybersecurity, ENISA, EU Data Protection Directive, EU Member States, EU Regulation, European Commission, European Union, Information Security, International, Online Privacy, Security Breach, Social Media

FTC Issues Staff Report on Mobile Privacy Disclosures and Announces Settlement with Social Networking Service for Mobile App Privacy Violations

Posted on February 1, 2013 by Hunton & Williams LLP

On February 1, 2013, the Federal Trade Commission issued a new report entitled Mobile Privacy Disclosures: Building Trust Through Transparency. The report makes recommendations “for the major participants in the mobile ecosystem as they work to improve mobile privacy disclosures,” offering specific recommendations for mobile platforms, app developers, advertising networks and other third parties operating in this space. The FTC’s report also makes mention of the Department of Commerce’s National Telecommunications and Information Administration’s efforts to engage in a multistakeholder process to develop an industry code of conduct for mobile apps.

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Tags: Consent Order, Consumer Protection, COPPA, Department of Commerce, Enforcement, Facebook, Federal Trade Commission, Information Security, Jon Leibowitz, Mobile App, Mobile Device, National Telecommunications and Information Administration, Obama, Online Privacy, Penalty, Privacy Policy, Social Media, Twitter

FFIEC Issues Draft Guidance on Social Media

Posted on January 25, 2013 by Hunton & Williams LLP

On January 23, 2012, the Federal Financial Institutions Examination Council (“FFIEC”) released proposed guidance, Social Media: Consumer Compliance Risk Management Guidance (the “Guidance”) to address how federal consumer protection laws may apply to the social media activities of financial institutions that are supervised by the Consumer Financial Protection Bureau. Comments on the guidance must be submitted within 60 days (before March 25, 2013). After consideration of the public comments, and once the guidance is finalized, financial institutions will be expected to “use the guidance in their efforts to ensure that their risk management practices adequately address the consumer compliance and legal risks, as well as related risks, such as reputation and operational risks, raised by activities conducted via social media.” Rather than imposing additional obligations on financial institutions, the Guidance is intended to help financial institutions comply with existing federal requirements as they apply to the use of social media platforms.

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Tags: Consumer Protection, Financial Privacy, Information Security, Social Media

EXIF Data That Raises Privacy Issues May Also Facilitate Transactions

Posted on January 7, 2013 by Hunton & Williams LLP

Reporting from Washington, D.C., Hunton & Williams associate Andrew Walsh writes:

Data embedded in photos can make a picture worth far more than a thousand words. To provide an example rich in irony, a well-known figure in Internet security who was wanted for police questioning recently inadvertently pinpointed his location for the authorities with an online posting of a photo containing Exchangeable Image File (“EXIF”) data. EXIF data is saved with JPG files on digital cameras and, if the camera has GPS, the EXIF data may include geolocation information such as the date, time, longitude, latitude and altitude of the photo.

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Tags: Geolocation, Mobile Device, Online Privacy, Social Media

FTC Releases Follow-up “Mobile Apps for Kids” Report

Posted on December 10, 2012 by Hunton & Williams LLP

On December 10, 2012, the Federal Trade Commission issued a new report, Mobile Apps for Kids: Disclosures Still Not Making the Grade, which follows up on the FTC’s February 2012 report, Mobile Apps for Kids: Current Privacy Disclosures are Disappointing. The FTC conducted a follow-up survey regarding pre-download mobile app privacy disclosures, and whether those disclosures accurately describe what occurs during use of the apps.

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Tags: COPPA, Data Processor, Enforcement, Federal Trade Commission, Geolocation, Mobile App, Mobile Device, Online Privacy, Privacy By Design, Social Media