Subscribe with Bloglines The Privacy Lawyer: FTC's Hooked on Phonics case...announced July 7, 2004

Thursday, July 08, 2004

FTC's Hooked on Phonics case...announced July 7, 2004

Hooked On Phonics and the FTC Enforcement Action
Parry's analysis of the FTC enforcement action and what this case means. Note that as in all cases, the facts are key. But we all need ot learn from Hooked on Phonics' mistakes...if you make a promise- keep it. If change your privacy policy, it only works going forward, not retroactively. And all privacy policies should have effective and last changed dates and an archive of changes.
The size of the fine, IMHO, means that the FTC didn't think that HOP acted in bad faith.

This is the first of the "material changes" cases for the FTC on website privacy policies. I expect more as we seek more guidance about what a site cna and can't do.

The best advice I can give you is to tag all data with the privacy limitations and any conditions of use under which that information was collected.

I think the FTC is one of the best governmental agencies in the world. They've done a great job here.



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