Halloween is approaching and there is more to be wary of than ghosts and goblins. The digital realm has its own pitfalls, and the recent FTC Case 2:22-cv-00073 serves as a chilling reminder. But fear not, for Assumed is here as your cover.
Table of Contents
What happened with FTC Case 2:22-cv-00073?
One fateful company found itself in the crosshairs of the FTC’s watchful gaze. As mentioned in Case 2:22-cv-00073, the company lacked a process to “seed” sensitive consumer information. “…has no program for investigating whether
sensitive consumer information it furnishes to potential purchasers is safeguarded
or used for purposes other than offering a loan. For example, “seeding” data by
adding unique dummy data is a common technique to detect leaks or breaches in
data security, and to monitor how data is being used.” This was not the primary reason for the FTC’s action, but it was important enough for them to list it in the Case.
The haunting reality
The FTC Case 2:22-cv-00073 highlighted that the mentioned company did not assess the content of policies and procedures of entities receiving consumer information. They should have ensured these policies were implemented effectively. This tale is a cautionary story for all in the digital realm, emphasizing the importance of implementing a process for ‘seeding’ your data.
Beyond Basic Compliance: What the FTC Expects
The FTC’s position in Case 2:22-cv-00073 shows its data protection expectations beyond mere policy documentation to active monitoring and verification. In this case, the FTC explicitly acknowledged seeding as a “common technique” for protecting consumer data, signaling its importance in modern data security practices.
The Commission expects companies to implement proactive measures that:
- Monitor how consumer data is being used
- Detect potential leaks or breaches in real-time
- Verify that data recipients handle information appropriately
- Protect consumers from unauthorized data use
Seeding databases directly addresses these expectations by creating traceable data points that act as silent sentinels.
The FTC Case 2:22-cv-00073 highlighted the absence of a seeding program as a security deficiency, indicating that the FTC views seeding not as optional but as a fundamental component of responsible data management.
Most importantly, companies must align with the FTC’s primary mission: protecting consumers. When companies seed their databases, they create an early warning system that prevents consumer harm before it occurs, rather than merely responding to breaches after the fact. This proactive stance represents the kind of consumer-first security measures the FTC seeks to encourage across industries.
Assumed: your guiding light in the darkness
Fret not; Assumed is here to assist so you do not share the same fate as the company mentioned:
- Seeding the Data: Assumed understands the power of “seeding” data. Using Assumed, you can detect unsolicited communication by embedding decoy data within genuine information, pinpointing potential leaks and their sources.
- Vetting Vendors: Using Assumed, you can not only use the contacts for your database, but also for vetting vendors and partners! By using a contact to fill out a form or “seeding” them in a list, you will have a bird’s eye view of what they are sending out. This feedback assists in protecting your business and knowing who to not work with.
- Continuous Monitoring: Assumed’s real-time monitoring keeps an eye, alerting businesses to potential breaches and allowing for swift action.
Concluding the tale
As the Halloween season unfolds, let the tale of FTC Case 2:22-cv-00073 be a reminder of what companies need to do with their data. Sign up for Assumed today and start “seeding” your data!