Tag Archives: reasonable

The FTC’s COPPA Guidance does an admirable job explaining the basics of what a business needs to do to comply with COPPA, but is vague as to how a business must protect personal information collected from children. The COPPA Guidance requires that a company use “reasonable procedures” to protect such information from unauthorized access or use, but does not explain what “reasonable procedures” means. This is,… More

I had the pleasure of moderating an excellent panel at the Advanced Cyber Security Center’s annual conference on November 4. The panel’s topic for discussion was “What is Reasonable in Cybersecurity: Responsibility and Accountability for Cybersecurity Practices.” I learned a great deal from our excellent panelists, Gus Coldebella (Fish & Richardson), Deborah Hurley (Harvard University), and John Krebs (Federal Trade Commission), as well as from the audience’s questions.… More