As discussed in the previous section, the FTC collects complaints about organizations that allegedly violate the data privacy, data security, advertising, and marketing laws.

Each month DPI creates a “Surge” report that identifies those organizations with the greatest increase in consumer complaint volume. For each organization listed the report indicates the quantity of complaints received in the past two months, the jurisdiction in which the organization is based, and a summary of the complaints filed. The following provides a snapshot of information concerning Surge reports and the FTC’s complaint database:

12

Number of organizations identified in a recent Surge Report.1

89.9%

Percentage of FTC enforcement actions that target an organization found in the FTC’s complaint database.2

Understanding the implications of the Surge Report to your organization:

  1. What is the typical month-to-month variation in your organization’s complaint volume?
  2. Does your typical variation indicate a high likelihood of being identified on a Surge Report?
  3. What is the typical month-to-month variation of your competitors?
  4. What is the typical month-to-month variation of your key clients?
  5. What is the typical month-to-month variation of your service providers?