Private Policy

hoose one and follow the instructions, posting your FTC case summary here. Remember to indicate which case you read.

Essay • 50 points

This document contains press releases for settlements entered into between the Federal Trade Commission (the US privacy law enforcement arm) and various website owners:

( QUESTION 1 PICTURE IS ATTACED AT THE BOTTOM)

***write a 5 sentence paragraph for question 1 its a essay***

2. In questions 2-11, you’ll analyze a privacy policy from a marketing perspective with an eye to legal compliance.

Choose One • 5 points

Congratulations! You’re on staff at NFL.com. You’ve been asked to access the site’s trade secret consumer database to meet various marketing objectives. Can the task be done without violating the company’s privacy policy, located at http://www.nfl.com/help/privacy, or jeopardizing the legal protection of the secret?

Your boss asks you to find out how many of the newsletter subscribers are opening promotional emails from NFL.com and its affiliates and whether there are any demographic trends (age, location, etc.) that indicate a likelihood of opening the email. Is this kind of data NFL.com collects from site visitors?

choose the correct answer

Yes—get going on it!

No—you’ll have to talk to IT and Legal about adding that functionality.

3. In questions 2-11, you’ll analyze a privacy policy from a marketing perspective with an eye to legal compliance.

Choose One • 5 points

Is consumer information disclosed or shared with anyone other than the website owner? If so, with whom and for what purposes?

choose the correct answer

Business that provide services to NFL.com (to perform their functions)

Third parties who make marketing offers to site visitors

Law enforcement

All of the above

4. In questions 2-11, you’ll analyze a privacy policy from a marketing perspective with an eye to legal compliance.

Choose One • 5 points

What should the team do if a child under 13 uploads information to the site or app?

choose the correct answer

Delete the information as soon as possible.

Use it just like it would use any other fan’s information.

5. In questions 2-11, you’ll analyze a privacy policy from a marketing perspective with an eye to legal compliance.

Choose One • 5 points

Can you share (no compensation changing hands) site visitor information consisting of email addresses, names, birthdates, operating systems, and geographic locations of NFL.com’s e-newsletter subscribers with the Baltimore Ravens?

choose the correct answer

Get going on it! The policy specifically allows this since they are affiliates.

Save the NFL! The policy prohibits this or doesn’t specifically address this—doing it would present a legal risk.

6. In questions 2-11, you’ll analyze a privacy policy from a marketing perspective with an eye to legal compliance.

Choose One • 5 points

A licensed apparel distributor who is not an NFL affiliate offers you a flat fee + commission on sales if NFL.com provides her with email addresses, names, birthdates, operating systems, and geographic locations of the team’s e-newsletter subscribers. Can you take her up on the offer?

choose the correct answer

Get going on it! The policy specifically allows this

Save the NFL! The policy prohibits this or doesn’t clearly address this—doing it would present a legal risk.

7. In questions 2-11, you’ll analyze a privacy policy from a marketing perspective with an eye to legal compliance.

Choose One • 5 points

NFL.com runs a contest with the winner getting club level season tickets. The contest is sponsored by one of the team’s major sponsors. Can the information collected on the contest entry form be shared with the sponsor?

choose the correct answer

Get going on it! The policy specifically allows this.

Save the NFL! The policy provides that you can share the information if the consumer consented, so you’ll want to first ensure that the list contains only those consumers who consented.

8. In questions 2-11, you’ll analyze a privacy policy from a marketing perspective with an eye to legal compliance.

Choose One • 5 points

If the NFL wants to use certain consumer information in a way that would violate the policy, it can change the policy to allow the new use. Under the terms of the NFL.com policy, how would it advise consumers of the new policy?

choose the correct answer

By posting the changes online or emailing account holders

The new policy is posted above the fold on the home page for 24 hours before taking effect

9. In questions 2-11, you’ll analyze a privacy policy from a marketing perspective with an eye to legal compliance.

Choose One • 5 points

Can you make an infographic covering location and demographic data of season ticket holders, newsletter subscribers and app subscribers to use as a marketing tool aimed at retailers?

choose the correct answer

Get going on it! The policy allows this.

Save the NFL! The policy prohibits this or doesn’t specifically address this—doing it would present a legal risk.

10. In questions 2-11, you’ll analyze a privacy policy from a marketing perspective with an eye to legal compliance.

Choose One • 5 points

NFL.com wants all employees to be able to review the consumer data it gathers and as well as what can be learned about NFL fans from that data. What steps can the organization take to boost its claim that the information is a protectable trade secret?

choose the correct answer

Telling employees that the data and analysis is the team’s trade secret

Having employees sign a confidentiality agreement when they are hired and remind them of it when they leave the team

Marking all files and documents “Confidential”

All of the above

11. In questions 2-11, you’ll analyze a privacy policy from a marketing perspective with an eye to legal compliance.

Choose One • 5 points

NFL.com’s consumer data analytics are a trade secret of the organization. Your boss asks you to send a copy of the latest report over to one of the NFL affiliates. What would be a smart question for you to ask before sending the report to ensure the affiliate knows not to further disclose or misuse the data and trends contained in that report?

choose the correct answer

Has the affiliate agreed to use the data?

Has the affiliate signed a confidentiality or non-disclosure agreement?

Has the affiliate agreed to pay for the data?

Do we trust the affiliate to do the right thing by this report?

ENTB376

Data Collection & Use Cases

The Federal Trade Commission (FTC) is the US agency on a mission to protect consumers and promote competition. The FTC protects consumers by stopping unfair, deceptive or fraudulent practices in the marketplace. It conducts investigations, sues companies and people that violate the law, develops rules to ensure a vibrant marketplace, and educates consumers and businesses about their rights and responsibilities. (FTC.gov website). This activity helps you understand the nature of unfair and deceptive trade practices cases undertaken by the FTC involving consumer data collection and use.

Instructions

Select a press release from the approved list below. Address the following points:

1. Describe how the website violated the law, why it was considered an unfair or deceptive trade practice and what penalty was imposed.

2. Explain whether you think the FTC was right or wrong and why you feel that way.

3. In one sentence, what is the lesson to be learned from this situation–what advice would you tell a website operator to reduce the risk of an FTC enforcement action while still achieving marketing or use goals?

Cases

1. Operator of Celebrity Fan Websites to Pay $1 Million to Settle FTC Charges that It Illegally Collected Children’s Information Without Their Parents’ Consent

2. FTC Charges That Security Flaws in RockYou Game Site Exposed 32 Million Email Addresses and Passwords

3. FTC Sends Educational Letters to Businesses to Help Them Prepare for COPPA Update

4. FTC Settles Charges Against Two Companies That Allegedly Failed to Protect Sensitive Employee Data

5. Iconix Brand Group Settles Charges Its Apparel Web Sites Violated Children’s Online

Privacy Protection Act

6. Fandango, Credit Karma Settle FTC Charges that They Deceived Consumers By Failing to

Securely Transmit Sensitive Personal Information

7. FTC Settlement Puts an End to “History Sniffing” by Online Advertising Network Charged

With Deceptively Gathering Data on Consumers

8. FTC Files Complaint Against Wyndham Hotels For Failure to Protect Consumers’ Personal

Information

Rev. 08/01/14 1

9. FTC Charges Operators of “Jerk.com” Website With Deceiving Consumers; FTC heads to trial against Jerk.com

10. Marketer of Internet-‐Connected Home Security Video Cameras Settles FTC Charges It

Failed to Protect Consumers’ Privacy

11. Myspace Settles FTC Charges That It Misled Millions of Users About Sharing Personal

Information with Advertisers

12. FTC Charges Businesses Exposed Sensitive Information on Peer-‐to-‐Peer File-‐Sharing

Networks, Putting Thousands of Consumers at Risk

13. Membership Reward Service Aimed at College Savers Settles FTC Charges That Its

‘TurboSaver Toolbar’ Feature Deceptively Collected Consumers’ Personal

Information

14. Facebook Settles FTC Charges That It Deceived Consumers By Failing To Keep

Privacy Promises

15. Online Advertiser Settles FTC Charges ScanScout Deceptively Used Flash Cookies to

Track Consumers Online

16. FTC Charges Deceptive Privacy Practices in Googles Rollout of Its Buzz Social

Network

17. Twitter Settles Charges that it Failed to Protect Consumers’ Personal Information; Company Will Establish Independently Audited Information Security Program

18. Dave & Buster’s Settles FTC Charges it Failed to Protect Consumers’ Information

19. CVS Caremark Settles FTC Charges:Failed to Protect Medical and Financial Privacy of Customers and Employees;CVS Pharmacy Also Pays $2.25 Million to Settle Allegations of HIPAA Violations

20. Google Will Pay $22.5 Million to Settle FTC Charges it Misrepresented Privacy

Assurances to Users of Apple’s Safari Internet Browser

21. Snapchat Settles FTC Charges That Promises of Disappearing Messages Were False
22. VIZIO to Pay $2.2 Million to FTC, State of New Jersey to Settle Charges It Collected Viewing Histories on 11 Million Smart Televisions without Users’ Consent

23. Digital Advertising Company Settles FTC Charges It Deceptively Tracked Consumers Both Online and Through Their Mobile Devices

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