FTC Actions, Breach Cases Guide COVID-19 Cyber Response - Law360

FTC Actions, Breach Cases Guide COVID-19 Cyber Response - Law360

Law360 (March 27, 2020, 5:37 PM EDT) --

Alysa Hutnik

Taraneh Marciano

William Pierotti

Many companies are rapidly implementing work-from-home policies in response to COVID-19, requiring many, if not all, of their employees to connect remotely to the organization’s computer network.

The sudden shift has been disruptive for companies and their employees alike, and malicious cyberactors like nothing better than a disruptive event. Indeed, recent reports have highlighted an increase in malicious phishing emails claiming to provide important updates or information about COVID-19.

Because bad actors often prey on the unwary during times of crisis, the dramatic increase in remote workers requires companies to be particularly diligent in protecting their systems and data. It’s a good time to also be reminded of best practices to help mitigate cyber and legal exposure in these unusual circumstances.

What Is Reasonable Security in 2020?

Under most applicable legal standards governing the protection of data security and data privacy, companies are required to take reasonable steps to secure their information technology systems and safeguard customer information. While this standard has evolved over time, it has generally required the use of encryption, firewalls and antivirus software, implementing security patches, limiting employees' access to information within the scope of their roles and responsibilities and training employees on cyber best practices, among other measures.

As further updated guidance, the Federal Trade Commission, in January, announced that its consent orders would be revamped to include additional provisions.[1] These settlement orders often provide direction to businesses on benchmarks for what the agency considers to be reasonable security practices.

Broadly speaking, recent FTC consent orders have impo ..

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