[At-Large] Consent Order FTC vs. Facebook on consumer privacy

Carlton Samuels carlton.samuels at gmail.com
Mon Aug 13 22:26:05 UTC 2012

The United States Federal Trade Commission (FTC) issued a consent order
binding Facebook to several actions in respect of privacy of FB users.
 This came on allegations that FB 'deceived consumers by telling them they
could keep their information on Facebook private, and then repeatedly
allowing it to be shared and made public.'

With its consent, FB is agreeing not misrepresent how it maintains the
privacy or security of users’ personal information; commit to obtain users’
“*affirmative express consent*” before sharing their information with any
third party that “materially exceeds the restrictions imposed by a user’s
privacy setting(s); to implement procedures to prevent a third party from
accessing users’ information no later than 30 days after the user has
deleted such information or terminated his or her account; establish,
implement and maintain a comprehensive privacy program; must obtain initial
and biennial assessments and reports regarding its privacy practices for
the next 20 years.

Here is the order in full:

One of the commissioners dissented, both on technical grounds and what
appears to be a pushback on the concept of 'plausible deniability' inherent
to US administrative law.  Here, his stated reasons for the dissent:

- Carlton Samuels

Carlton A Samuels
Mobile: 876-818-1799
*Strategy, Planning, Governance, Assessment & Turnaround*

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