The Federal Financial Institutions Examination Council (FFIEC) has released final supervisory guidance on the use of social media by financial institutions. We last reported on the guidance when it was published in draft form in January 2013. The final guidance is substantially similar to the proposal (and we encourage you to read our prior post for more details on the elements of the guidance), but the FFIEC made certain revisions in light of the 81 public comments it received on the proposal.
Category Archives: Social Media
Subscribe to Social Media RSS FeedHogan Lovells’ IAPP Tracker Post Highlights Impact of California Privacy Legislation
This post describes the whirlwind of recently enacted and currently debated privacy legislation in California, including new online protections for minors, amendments to breach notification requirements, and new online privacy policy requirements.
IAPP Piece Explores Jurisdictional Implications of French Court’s Privacy/Hate Speech Dilemma
On June 12, a French Court of Appeals upheld a decision ordering Twitter to divulge the identities of the authors of anti-Semitic tweets, which are illegal under French law. In a detailed analysis of the court’s order for the IAPP Privacy Perspectives blog, Winston Maxwell and Christopher Wolf describe how the order, issued directly by the French court to California-based Twitter, which does not have a French establishment, implicates jurisdictional issues and calls into question the use of anonymity as a privacy shield to post hate speech online.
IAPP Piece Explores Intersection of Privacy/Anonymity and Hate Speech
Anonymity can provide internet users with benefits but can also facilitate the publishing of hurtful or hateful comments online, reports Hogan Lovells privacy leader Chris Wolf in a recent post on the blog of the International Association of Privacy Professionals, Privacy Perspectives. The post discusses Chris’ new book investigating online hate speech, Viral Hate: Containing its Spread on the Internet, with a focus on the tension between online anonymity and the prevention of hate speech.
Federal Court Certifies 60,000-Member Class in “Wireless Spam” TCPA Litigation against Insurance Company, for Actions of Its Marketing Vendors
In a decision with important implications for companies that hire outside marketing firms, a federal judge has certified a class of nearly 60,000 individuals who allegedly received an unsolicited text message from a marketing company hired by Stonebridge Life Insurance Company. The plaintiff in Lee v. Stonebridge Life Insurance Company and Trifecta Marketing Company, LLC, 3:11-cv-00043 (N.D. […]
FTC Releases Mobile Privacy Report and Announces Settlement with Mobile App Operator
Today the FTC released Mobile Privacy Disclosures: Building Trust Through Transparency, a report containing recommendations for the mobile industry. The report encourages mobile app platforms to play a significant role in providing consumers with privacy-related information, devoting more pages to recommendations for platforms than it does for developers, ad networks, third-party service providers, and trade […]
Bank Regulators Propose Social Media Guidance; Comments Due March 25, 2013
The Federal Financial Institutions Examination Council (FFIEC) has released proposed guidance on the use of social media by financial institutions, including banks, credit unions, and non-bank entities supervised by the Consumer Financial Protection Bureau. The proposed “Social Media: Consumer Compliance Risk Management Guidance” (“Proposed Guidance”) defines “social media” broadly to including micro-blogging sites (like Google […]