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Well, the consent decree should then say: you need to do X testing, Y review. If they did that, it's still not a violation.
by johndhi 3y ago
Well, the consent decree should then say: you need to do X testing, Y review. If they did that, it's still not a violation.
- johndhi 3y agoYou can read the text of the consent decree here [1]. Looks like it just generally required them to have a 'privacy program' and to monitor and test their vendors. [1] https://www.ftc.gov/system/files/ftc_gov/pdf/c4365facebookproposedmodifieddecisionandorder.pdf https://www.ftc.gov/system/files/ftc_gov/pdf/c4365facebookpr...
- dragonwriter 3y ago> Well, the consent decree should then say: you need to do X testing, Y review. The consent decree can just say you have to not do Z. You take whatever steps are necessary to avoid that. If you do it “accidentally” that’s a violation. The point of a consent decree, from the point of viee of the regulatort agency, is generally to eliminate excuses for a party already seen as a violator as a condition to hold off on an existing enforcement action for the violation. Creating opportunities for technical compliancd while the problem sought to be avoided still occurs is an explicit non-goal. (From the non-government side, the point is to avoid greater penalties now by accepting some obligations and limitations going forward.)