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Cybersecurity Regulation Technology Media and Telecom

Lessons Learned from Recent FTC Data Security Enforcement Orders

Proposed class actions against Zoom are illustrative of a challenge many businesses face: what is “reasonable” data security? The FTC’s key data-security-related enforcement can help guide businesses in developing their data security programs.


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Amid the nation-wide “work from home” routine necessitated by the COVID-19 pandemic, an extraordinary number of businesses turned to the Zoom Video Communications’ video conferencing platform. As the use of the Zoom platform increased, so did scrutiny of Zoom’s data security practices, which in turn produced a flurry of class action lawsuits against Zoom for “violation of its duty to implement and maintain reasonable security procedures and practices.” Like many technology providers, Zoom’s Terms of Service (update as of April 13, 2020) stated that Zoom will “maintain reasonable physical and technical safeguards to prevent unauthorized disclosure of or access … in accordance with industry standards.”

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