On January 21, 2015, the FTC Director briefed companies that use targeted advertising, as to how to avoid legal problems with the FTC and other authorities. As part of the brief, the Director underscored the following principles:

  • Fully disclose tracking technologies and practices:  companies should verify a business partner’s privacy and verify that service providers adequately protect personal information;
  • Provide an easy to find privacy policy, as well as key information and choices at the time that consumers are providing their data or making other decisions about it; and
  • Putting into practice “Privacy by Design” principles: insert build-in privacy protections at every stage of the development of the product (e.g. limit data collection and retention, de-identification of data, etc.).