Tomorrow's Jobs Today
The competition for the Information Management 2019 IMT MVP Awards was tight – and congrats are in order to all of our winners! We got to know one of them, a bit better here! Read the winning articles here: http://bit.ly/IMTAwards2019
The 2019 Information Management Today MVP Awards Winners Spotlight from Shelley Trout on Vimeo.
It gives me great pleasure to shout from the digital mountaintop that along with my co-author, Abby Moscatel, Esq., we’ve signed a book deal with John Hunt Publishing to release our book, Tomorrow’s Jobs Today: Wisdom and Career Advice from Thought Leaders in AI, Big Data, Blockchain, the Internet of Things, Privacy, and More. The manuscript originated from a series of in-depth interviews we’ve been conducting around the world. The insights that emerged from these conversations were so essential and relevant to workers in the Information Age that we knew we just had to share it with a bigger audience!
This collection of in-depth profiles featuring Smart City CIOs, Data Protection Officers, Blockchain CEO’s, Informatics Doctors and other diverse, skilled professionals gives readers first-hand insight into what tomorrow’s jobs look like today. The hands-on experiences, subject matter expertise, and measured job advice shared within these pages demonstrate how identifying opportunities, setting the right cadence, and building strong relationships are the essential ingredients to unlocking your future’s potential.
This book is for the new graduate, the professional between jobs and the doting parents desperate to get their “brilliant” but lazy kid out of the basement. It’s also for senior corporate leaders seeking an intimate understanding of the changes abounding in their organizations. It’s for the manager who wants to inspire and encourage professional development. And it’s for every knowledge worker out there who wants to leverage technology and information governance to reduce risk, generate revenue, and improve customer experiences.
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In today’s data-driven, fast-changing world, Tomorrow’s Jobs Today gives business leaders a solid overview of many complex technology trends. This book helps surface many of the issues a business leader needs to be aware of and provides food for thought on how they might be navigated as we head into a new decade. –Gregory L. Steinhauer, President, American Life
Information is the currency that fuels and funds the Digital Transformation journey. Tomorrow’s Jobs Today manages to capture a set of leadership perspectives that, while diverse, share an essential characteristic for the future of transformative work: leveraging information as one’s most valuable asset. –Peggy Winton, CEO, Association for Intelligent Information Management AIIM
If you want to stay successful, you have to embrace and adapt to changes. Tomorrow’s Jobs Today shows you how those challenges can be both enlightening and empowering. –Jim Dodson, SVP, Iron Mountain
In a world often seized by ever-accelerating change, Tomorrow’s Jobs Today has brilliantly identified, captured, and recounted liberating insights for success from a broad range of global information governance and technology professionals. There will always be challenges, but for those willing to look, the opportunity is abundant. The Information Age remains an ever-growing frontier awaiting each new wave of pioneers. –Seth Williams, President, MER Conference
This is an empowering and beautifully written book that will surely guide the reader to find a place in this quickly changing Information Age, where they can thrive and contribute to the greater good. –Dr. Angela Bair Schmider, M.S., Ph.D., Massachusetts General Hospital and Harvard Medical School
The authors bring together the voices of leading thinkers, exploring the critical themes that will dominate the years to come. Entertaining interviews reveal the best paths forward for professional development and the impending social, political, and ethical challenges of tomorrow. This is an important book. –Alex Panagides, CEO, mxHero
Tomorrow’s Jobs Today brings together an impressive group of professionals sharing their wisdom and career advice from the cutting edge of technological advancement today. These insights will inevitably bolster your career path, and the combined knowledge of so many brilliant folks in one volume is staggering. I recommend this book for anyone who is pushing or looking to push their organizations into the future. –Nick Inglis, Executive Director of Content & Programming, ARMA International
Stepping away from the mush of data that sometimes arrives through surveys, Tomorrow’s Jobs Today goes straight to the people creating the future world of work. Read this book; go interview a few visionaries yourself; help shape the world to come. –Andy Watson, Head of School, Albuquerque Academy
About John Hunt Publishing – John Hunt’s Business Books “Fresh thinking for the business world,” imprint publishes practical guides and insightful non-fiction for beginners and professionals. Covering aspects from management skills, leadership, and organizational change to positive work environments, career coaching, and self-care for managers, our books are a valuable addition to those working in the world of business.
This year’s conference takes place May 4-6th in Chicago and features Information Governance sessions on Privacy, eDiscovery, Data Remediation, emerging technologies, and operational best practices from the industry’s leading experts, along with the experiences of knowledgeable practitioners.
Tackling data privacy and maintaining consumer trust is harder than ever, especially with the sheer amount of information you need to manage and with constantly evolving privacy laws (CCPA, GDPR, etc) moving the goalposts. The usual checkbox compliance, ad-hoc governance, and reactive information security policies will fail, if they haven’t already, and create too much organizational risk. To achieve a state of consistent compliance and minimize corporate risk you must provide three things to your business: transparent governance, frictionless security, and continuous validation. To provide these things, you must build a strong information governance framework and privacy compliance plan to succeed.
This special, two-part panel discussion facilitated by the ICRM will compare current academic curricula with the existing ICRM exam to identify gaps and areas of improvements for both academia and the ICRM. University Professors will discuss their programs and IG industry leaders will add perspective from the business world. There will be ample time for members of the audience to share their thoughts as well. It is time to close any gaps between what is taught at the university level and what is needed in the world of business. More effective preparation of the next generation of IG professionals will benefit all organizations that depend on these practitioners to address the business opportunities and challenges of the future and it will provide more fulfilling careers for those emerging from school into the world of business.
Also, our partners at Ethikos will be coming all the way from Brussels to present on GDPR.
The GDPR will celebrate its second anniversary on 25 May 2020 – a good time for US companies impacted by this regulation to understand what they should expect in the coming months. In this presentation, Legal professionals working in Europe will discuss how the GDPR has been enforced so far in Europe, what the regulators’ future direction might be, and the key areas US organizations will need to focus on in the coming months. Is there a higher risk of enforcement on the horizon? What is the level of privacy awareness among Internet users, consumers and individuals in Europe? Should US organizations that collect and process personal data of EU data subjects be worried about these regulatory trends?
“California Consumer Privacy Act – Now What Do We Do?”
Register here: https://zoom.us/webinar/register/WN_inuTshVvT9SAQ_XGa
Learn: Why data protection and privacy are important to my business What to do in case of a data breach Preparation for a cyber-attack Preparation for CCPA Preparation for PII/PHI breach response
When: Wednesday, Jan. 22, 2020 Time: 10 a.m. PST/1 p.m. EST
The FTC alleged that Unrollme Inc., which helps users unsubscribe from unwanted emails or consolidate their email subscriptions, falsely told consumers that it would not “touch” their personal emails in order to persuade consumers to provide access to their email accounts.
In fact, Unrollme shared users’ email receipts from completed transactions with Unrollme’s parent company, Slice Technologies, Inc. E-receipts can include, among other things, the user’s name, billing and shipping addresses, and information about products or services purchased by the consumer. Slice uses anonymous purchase information from Unrollme users’ e-receipts in the market research analytics products it sells.
As part of the settlement with the Commission, Unrollme is prohibited from misrepresenting the extent to which it collects, uses, stores, or shares information from consumers. It must also notify those consumers who signed up for Unrollme after viewing one of the allegedly deceptive statements about how it collects and shares information from e-receipts. The order also requires Unrollme to delete, from both its own systems and Slice’s systems, stored e-receipts previously collected from those consumers, unless it obtains their affirmative, express consent to maintain the e-receipts.
After receiving two comments, the Commission voted 4-0-1 to approve the settlement with Unrollme as well as responses to the commenters. Commissioner Rohit Chopra abstained from the vote.
Rafael Moscatel is Managing Director of Compliance and Privacy Partners, a consulting firm specializing in data governance and privacy solutions. He is an award-winning Information Governance Professional (IGP), Certified Records Manager (CRM), Certified Information Privacy Manager (CIPM). Rafael has spent the last twenty years developing large-scale Information Management Programs for the Fortune 500 including Paramount Pictures and Farmers Insurance. Reach him at 323-413-7432, follow him on Twitter at @rafael_moscatel or visit http://www.capp-llc.com to learn more.
We’ve all been there. Sitting around the conference room with our compliance teams, droning on about scheduling conflicts, procedural details and strategy about strategy. Here are some actual substantive ideas, initiatives and approaches to privacy, data governance and cyber-security that can get the ball rolling next year.
For example:
Executives need to make sure they are told what they need to hear, not what they want to hear.
Lack of procedural consistency, ownership of policy and overlap and confusion over a directives authority in can create even more conflict, risk and uncertainty for an organization. But relying on institutional knowledge and spreadsheets just doesn’t cut it anymore. That’s why every regulated company needs a strong technology backbone in the form of a GRC or governance risk and compliance software.
Organizations need strategies and tools to help them prioritize and manage those vendor risks effectively. Sophisticated and affordable tools that address consumer data privacy requests can also be used to map and streamline an organizations external data, whether it’s private in nature or otherwise.
Rafael Moscatel is Managing Director of Compliance and Privacy Partners, a consulting firm specializing in data governance and privacy solutions. He is an award-winning Information Governance Professional (IGP), Certified Records Manager (CRM), Certified Information Privacy Manager (CIPM). Rafael has spent the last twenty years developing large-scale Information Management Programs for the Fortune 500 including Paramount Pictures and Farmers Insurance. Reach him at 323-413-7432, follow him on Twitter at @rafael_moscatel or visit http://www.capp-llc.com to learn more.
ICRM will not only conduct their spring Board and Business meetings at the MER Conference next May in Chicago, but will also facilitate a panel discussion “Meeting Evolving Business Needs: A Conversation Between RIM Educators and Thought Leaders.”
The panel of experts include: John Isaza, Esq, FAI, Rafael Moscatel, CRM, IGP, CIPM, and Wendy McLain, MLIS, CRM. The panel of Academic Partners include: Patricia Franks, Ph.D, CRM, CA, IGP – San Jose State University; Gregory S. Hunter, Ph.D, CA, CRM, FSAA – Long Island University, Palmer School of Library and Information Science, and Tao Jin, Ph.D – Louisiana State University, School of Library and Information Science.
The desired outcome is to expand and nurture an ongoing and productive dialogue between our profession and academic institutions to ensure graduates are well prepared to fill current and future positions in key areas of Records and Information Management (RIM) and Information Governance (IG). If interested in joining us at the MER Conference – go to their website and register for conference. https://www.merconference.com/
The Federal Trade Commission is extending the deadline to submit comments on the agency’s review of the Children’s Online Privacy Protection Act Rule (COPPA Rule) until December 11, 2019.
The federal government’s Regulations.gov portal is temporarily inaccessible. The FTC is giving commenters additional time to submit comments, as well as an alternative mechanism to file them. Those unable to submit comments via Regulations.gov can submit them via email with the subject line “COPPA comment” to secretary@ftc.gov. All comments, whether filed through Regulations.gov or sent by email, must be submitted by11:59 p.m. ET on December 11, 2019.
The Commission voted 5-0 to extend the comment deadline until December 11, 2019.
Rafael Moscatel, CRM, IGP, is the Managing Director of Compliance and Privacy Partners, LLC. Reach him at 323-413-7432, follow him on Twitter at @rafael_moscatel or visit http://www.capp-llc.com to learn more.
Reward of up to $5 Million Offered for Information Leading to Arrest or Conviction
The United States of America, through its Departments of Justice and State, and the United Kingdom, through its National Crime Agency (NCA), today announced the unsealing of criminal charges in Pittsburgh, Pennsylvania, and Lincoln, Nebraska, against Maksim V. Yakubets, aka online moniker, “aqua,” 32, of Moscow, Russia, related to two separate international computer hacking and bank fraud schemes spanning from May 2009 to the present. A second individual, Igor Turashev, 38, from Yoshkar-Ola, Russia, was also indicted in Pittsburgh for his role related to the “Bugat” malware conspiracy. The State Department, in partnership with the FBI, announced today a reward of up to $5 million under the Transnational Organized Crime Rewards Program for information leading to the arrest and/or conviction of Yakubets. This represents the largest such reward offer for a cyber criminal to date.
Assistant Attorney General Brian A. Benczkowski of the Justice Department’s Criminal Division, U.S. Attorney Scott W. Brady for the Western District of Pennsylvania, U.S. Attorney Joseph P. Kelly for the District of Nebraska, FBI Deputy Director David Bowdich, Principal Deputy Assistant Secretary James A. Walsh of the State Department’s Bureau of International Narcotics and Law Enforcement Affairs (INL), and Director Rob Jones of the Cyber Crime Unit at the United Kingdom’s National Crime Agency (NCA) made the announcement.
“Maksim Yakubets allegedly has engaged in a decade-long cybercrime spree that deployed two of the most damaging pieces of financial malware ever used and resulted in tens of millions of dollars of losses to victims worldwide,” said Assistant Attorney General Benczkowski. “These two cases demonstrate our commitment to unmasking the perpetrators behind the world’s most egregious cyberattacks. The assistance of our international partners, in particular the National Crime Agency of the United Kingdom, was crucial to our efforts to identify Yakubets and his co-conspirators.”
“For over a decade, Maksim Yakubets and Igor Turashev led one of the most sophisticated transnational cybercrime syndicates in the world,” said U.S. Attorney Brady. “Deploying ‘Bugat’ malware, also known as ‘Cridex’ and ‘Dridex,’ these cybercriminals targeted individuals and companies in western Pennsylvania and across the globe in one of the most widespread malware campaigns we have ever encountered. International cybercriminals who target Pennsylvania citizens and companies are no different than any other criminal: they will be investigated, prosecuted and held accountable for their actions.”
“The Zeus scheme was one of the most outrageous cybercrimes in history,” said U.S. Attorney Kelly. “Our identification of Yakubets as the actor who used the moniker ‘aqua’ in that scheme, as alleged in the complaint unsealed today, is a prime example of how we will pursue cyber criminals to the ends of justice no matter how long it takes, by tracking their activity both online and off and working with our international partners to expose their crimes.”
“Today’s announcement involved a long running investigation of a sophisticated organized cybercrime syndicate,” said FBI Deputy Director Bowdich. “The charges highlight the persistence of the FBI and our partners to vigorously pursue those who desire to profit from innocent people through deception and theft. By calling out those who threaten American businesses and citizens, we expose criminals who hide behind devices and launch attacks that threaten our public safety and economic stability. The actions highlighted today, which represent a continuing trend of cyber-criminal activity emanating from Russian actors, were particularly damaging as they targeted U.S. entities across all sectors and walks of life. The FBI, with the assistance of private industry and our international and U.S. government partners, is sending a strong message that we will work together to investigate and hold all criminals accountable. Our memory is long and we will hold them accountable under the law, no matter where they attempt to hide.”
“Combatting cybercrime remains a top national security priority for to the United States,” said INL Principal Deputy Assistant Secretary of State Walsh. “The announcements today represent a coordinated interagency effort to bring Maksim Yakubets to justice and to address cybercrime globally.”
“This is a landmark for the NCA, FBI and U.S. authorities and a day of reckoning for those who commit cybercrime,” said NCA Director Jones. “Following years of online pursuit, I am pleased to see the real world identity of Yakubets and his associate Turashev revealed. Yakubets and his associates have allegedly been responsible for losses and attempted losses totalling hundreds of millions of dollars. This is not a victimless crime, those losses were once people’s life savings, now emptied from their bank accounts. Today the process of bringing Yakubets and his criminal associates to justice begins. This is not the end of our investigation, and we will continue to work closely with international partners to present a united front against criminality that threatens our prosperity and security.”
Yakubets and Turashev Indicted in Relation to “Bugat” Malware
A federal grand jury in Pittsburgh returned a 10-count indictment, which was unsealed today, against Yakubets and Turashev, charging them with conspiracy, computer hacking, wire fraud, and bank fraud, in connection with the distribution of “Bugat,” a multifunction malware package designed to automate the theft of confidential personal and financial information, such as online banking credentials, from infected computers. Later versions of the malware were designed with the added function of assisting in the installation of ransomware.
According to the indictment, Bugat is a malware specifically crafted to defeat antivirus and other protective measures employed by victims. As the individuals behind Bugat improved the malware and added functionality, the name of the malware changed, at one point being called “Cridex,” and later “Dridex,” according to the indictment. Bugat malware was allegedly designed to automate the theft of confidential personal and financial information, such as online banking credentials, and facilitated the theft of confidential personal and financial information by a number of methods. For example, the indictment alleges that the Bugat malware allowed computer intruders to hijack a computer session and present a fake online banking webpage to trick a user into entering personal and financial information.
The indictment further alleges that Yakubets and Turashev used captured banking credentials to cause banks to make unauthorized electronic funds transfers from the victims’ bank accounts, without the knowledge or consent of the account holders. They then allegedly used persons, known as “money mules,” to receive stolen funds into their bank accounts, and then move the money to other accounts or withdraw the funds and transport the funds overseas as smuggled bulk cash. According to the indictment, they also used a powerful online tool known as a botnet in furtherance of the scheme.
Yakubets was the leader of the group of conspirators involved with the Bugat malware and botnet, according to the indictment. As the leader, he oversaw and managed the development, maintenance, distribution, and infection of Bugat as well as the financial theft and the use of money mules. Turashev allegedly handled a variety of functions for the Bugat conspiracy, including system administration, management of the internal control panel, and oversight of botnet operations.
According to the indictment, Yakubets and Turashev victimized multiple entities, including two banks, a school district, and four companies including a petroleum business, building materials supply company, vacuum and thin film deposition technology company and metal manufacturer in the Western District of Pennsylvania and a firearm manufacturer. The indictment alleges that these attacks resulted in the theft of millions of dollars, and occurred as recently as March 19, 2019.
Yakubets Charged in Relation to “Zeus” Malware
A criminal complaint was also unsealed in Lincoln today charging Yakubets with conspiracy to commit bank fraud in connection with the “Zeus” malware. Beginning in May 2009, Yakubets and multiple co-conspirators are alleged to have a long-running conspiracy to employ widespread computer intrusions, malicious software, and fraud to steal millions of dollars from numerous bank accounts in the United States and elsewhere. Yakubets and his co-conspirators allegedly infected thousands of business computers with malicious software that captured passwords, account numbers, and other information necessary to log into online banking accounts, and then used the captured information to steal money from victims’ bank accounts. As with Bugat, the actors involved with the Zeus scheme were alleged to have employed the use of money mules and a botnet.
Yakubets and his co-conspirators are alleged to have victimized 21 specific municipalities, banks, companies, and non-profit organizations in California, Illinois, Iowa, Kentucky, Maine, Massachusetts, New Mexico, North Carolina, Ohio, Texas, and Washington, identified in the complaint, including multiple entities in Nebraska and a religious congregation. According to the complaint, the deployment of the Zeus malware resulted overall in the attempted theft of an estimated $220 million USD, with actual losses of an estimated $70 million USD from victims’ bank accounts. According to the complaint, Yakubets’ role in the Zeus scheme was to provide money mules and their associated banking credentials in order to facilitate the movement of money, which was withdrawn from victim accounts by fraudulent means.
An individual charged as John Doe #2, also known as “aqua,” was indicted in District of Nebraska in case number 4:11-CR-3074. The indictment in that case charges that individual and others with conspiracy to participate in racketeering activity, conspiracy to commit computer fraud and identity theft, aggravated identity theft, and multiple counts of bank fraud related to the Zeus scheme. As alleged, the complaint unsealed today associates use of the moniker “aqua” in the Zeus scheme to Yakubets.
In case number 4:11-CR-3074, two of the co-conspirators of “aqua,” Ukrainian nationals Yuriy Konovaleko and Yevhen Kulibaba, were extradited from the United Kingdom to the United States. Konovalenko and Kulibaba both pleaded guilty in 2015 to conspiracy to participate in racketeering activity and have completed prison sentences that were imposed. Konovalenko and Kulibaba were previously convicted in the United Kingdom, after an investigation conducted by the Metropolitan Police Service, for their role in laundering £3 million GBP on behalf of the group responsible for the Zeus malware.
State Department $5 million USD Reward
The U.S. Department of State’s Transnational Organized Crime (TOC) Rewards Program is offering a reward of up to $5 million for information on Yakubets. Cyber threats are a top national security threat to the United States, and the Department of State’s TOC Rewards Program is one of the many tools used by U.S. authorities to bring significant cybercriminals to justice. Congress established the TOC Rewards Program in 2013 to support law enforcement efforts to dismantle transnational criminal organizations and bring their leaders and members to justice. The U.S. Department of State’s Bureau of International Narcotics and Law Enforcement Affairs manages the program in coordination with other U.S. federal agencies.
In addition to NCA, the law enforcement actions taken related to these two prosecutions were assisted by the efforts of law enforcement counterparts from The Netherlands, Germany, Belarus, Ukraine, and the Russian Federation.
The FBI’s Pittsburgh and Omaha Field Offices led the investigations of Yakubets and Turashev with assistance by the FBI’s Major Cyber Crimes Unit and Global Operations and Targeting Unit. The prosecution in Pittsburgh is being handled by Assistant U.S. Attorney Shardul S. Desai of the Western District of Pennsylvania, and the prosecution in Lincoln is being handled by Senior Counsel William A. Hall, Jr., of the Criminal Division’s Computer Crime and Intellectual Property Section (CCIPS) and Assistant U.S. Attorney Steven A. Russell of the District of Nebraska. The Criminal Division’s Office of International Affairs provided significant assistance throughout the criminal investigations. The Department’s National Security Division also provided investigative assistance.
The details contained in the indictment, criminal complaint and related pleadings are merely accusations, and the defendants are presumed innocent unless and until proven guilty beyond a reasonable doubt in a court of law.
The Federal Trade Commission issued an Opinion finding that the data analytics and consulting company Cambridge Analytica, LLC engaged in deceptive practices to harvest personal information from tens of millions of Facebook users for voter profiling and targeting. The Opinion also found that Cambridge Analytica engaged in deceptive practices relating to its participation in the EU-U.S. Privacy Shield framework.
In an administrative complaint filed in July, FTC staff alleged that Cambridge Analytica and its then-CEO Alexander Nix and app developer Aleksandr Kogan deceived consumers. Nix and Kogan agreed to settle the FTC’s allegations. Cambridge Analytica, which filed for bankruptcy in 2018, did not respond to the complaint filed by FTC staff, or a motion submitted for summary judgment of the allegations.
The FTC staff’s administrative complaint alleged that Kogan worked with Nix and Cambridge Analytica to enable Kogan’s GSRApp to collect Facebook data from app users and their Facebook friends. The complaint alleged that app users were falsely told the app would not collect users’ names or other identifiable information. The GSRApp, however, collected users’ Facebook User ID, which connects individuals to their Facebook profiles.
The complaint also alleged that Cambridge Analytica claimed it participated in the EU-U.S. Privacy Shield—which allows companies to transfer consumer data legally from European Union countries to the United States—after allowing its certification to lapse. In addition, the complaint alleged the company failed to adhere to the Privacy Shield requirement that companies that cease participation in the Privacy Shield affirm to the Department of Commerce, which maintains the list of Privacy Shield participants, that they will continue to apply the Privacy Shield protections to personal information collected while participating in the program.
In its Opinion, the Commission found that Cambridge Analytica violated the FTC Act through the deceptive conduct alleged in the complaint. The Final Order prohibits Cambridge Analytica from making misrepresentations about the extent to which it protects the privacy and confidentiality of personal information, as well as its participation in the EU-U.S. Privacy Shield framework and other similar regulatory or standard-setting organizations. In addition, the company is required to continue to apply Privacy Shield protections to personal information it collected while participating in the program (or to provide other protections authorized by law), or return or delete the information. It also must delete the personal information that it collected through the GSRApp.
The Commission voted 5-0 to issue the Opinion and Final Order.
Rafael Moscatel, CRM, IGP, is the Managing Director of Compliance and Privacy Partners, LLC. Reach him at 323-413-7432, follow him on Twitter at @rafael_moscatel or visit http://www.capp-llc.com to learn more.
Article reprinted below!
Content may still be king, but now the rights to some of it may belong to the people! In response to the EU’s General Data Protection Requirement (GDPR) and recent stateside efforts to enshrine data protection including the California Consumer Privacy Act (CCPA), organizations are revisiting the efficacy of their Data and Information Governance (IG) programs. Laws and regulations vary by industry and company size but each intend to protect consumer’s personal data by prescribing technical and governance standards backed by stiff penalties for non-compliance.
Notably, while many companies are already familiar with records retention laws, these latest controls also introduce a duty to destroy data once no longer required for a legitimate business purpose. For entities that have grown accustomed to leveraging cheap digital storage, this new responsibility presents a number of logistical hurdles.
However, directives on how you may use your customer’s data or any other information you store doesn’t necessarily have to be burdensome. In fact, these new guardrails present numerous opportunities to implement better governance, monetize the lifecycle of information assets and foster trustworthy relationships that can actually enhance the customer experience.
These 7 tips can help prepare your data to support an IG strategy:
By complementing policy frameworks and toolsets with the types of Information Governance approaches noted here we can better enable our workforce to hone their knowledge skills, achieve defensible destruction and improve audit outcomes. In effect, we are future proofing ourselves for a business world destined to face increased scrutiny and under siege from data breaches and privacy issues with seemingly no end in sight. IG is the bright light at the end of that tunnel.
Rafael Moscatel, CRM, IGP, is the Managing Director of Compliance and Privacy Partners, LLC. Reach him at 323-413-7432, follow him on Twitter at @rafael_moscatel or visit http://www.capp-llc.com to learn more.
The Federal Trade Commission has reached settlements with four companies that allegedly misrepresented their participation in the EU-U.S. Privacy Shield framework, which enables companies to transfer consumer data legally from European Union countries to the United States. The FTC also alleged that two of the companies failed to comply with Privacy Shield requirements.
In separate actions, the FTC settled Privacy Shield cases against:
In addition to allegations that each company falsely claimed to participate in the EU-U.S. Privacy Shield framework, the FTC also alleged that Click Labs and Incentive Services falsely claimed to participate in the Swiss-U.S. Privacy Shield framework, which establishes a process for companies to transfer consumer data in compliance with Swiss law.
In its cases against Global Data and TDARX, the FTC further alleged that the companies continued to claim participation in EU-U.S. Privacy Shield after allowing their certifications to lapse, and that those companies failed to comply with the framework. The companies allegedly failed to verify annually that statements about their Privacy Shield practices were accurate, and failed to affirm that they would continue to apply Privacy Shield protections to personal information collected while participating in the program.
“The Privacy Shield Framework is critical to facilitating transatlantic commerce and assuring our European partners of our commitment to data protection,” said Andrew Smith, Director of the FTC’s Bureau of Consumer Protection. “Enforcement of the Privacy Shield framework is a priority of the FTC, and we will hold companies accountable where, as here, they fail to keep their Privacy Shield promises.”
The Department of Commerce administers both the EU-U.S. and Swiss-U.S. Privacy Shield frameworks, while the FTC enforces the promises companies make when joining the programs. With today’s announcement, the FTC has now brought a total of 21 enforcement actions related to the EU-U.S. Privacy Shield framework since it was established in 2016.
Under the settlements, all four companies are prohibited from misrepresenting their participation in the EU-U.S. Privacy Shield framework, as well as any other privacy or data security program sponsored by any government, or any self-regulatory or standard-setting organization. As part of their settlements, Global Data Vault and TDARX also are required to continue to apply the Privacy Shield protections to personal information they collected while participating in the program, or return or delete the information.
The Commission voted 5-0 to issue the proposed administrative complaints and to accept the consent agreements with the four companies. The FTC will publish a description of the consent agreement packages in the Federal Register soon. The agreements will be subject to public comment for 30 days after publication in the Federal Register after which the Commission will decide whether to make the proposed consent orders final. Once processed, comments will be posted on Regulations.gov.
NOTE: The Commission issues an administrative complaint when it has “reason to believe” that the law has been or is being violated, and it appears to the Commission that a proceeding is in the public interest. When the Commission issues a consent order on a final basis, it carries the force of law with respect to future actions. Each violation of such an order may result in a civil penalty of up to $42,530.
