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The Changing Nature of the FTCs Alexis Goltra, Vice President, Legal - PowerPoint PPT Presentation

October 15, 2019 The Changing Nature of the FTCs Alexis Goltra, Vice President, Legal & Chief Privacy and Data Security Orders, Privacy Officer the Rising Specter of Individual Oracle Liability, and the Future of FTC Authority and


  1. October 15, 2019 The Changing Nature of the FTC’s Alexis Goltra, Vice President, Legal & Chief Privacy and Data Security Orders, Privacy Officer the Rising Specter of Individual Oracle Liability, and the Future of FTC Authority and Enforcement Reed Freeman, Partner WilmerHale Nicole Ewart, Counsel WilmerHale

  2. Speaker Alexis Goltra Vice President, Legal & Chief Privacy Officer Oracle Corporation

  3. Speaker Reed Freeman Partner WilmerHale

  4. Speaker Nicole Ewart Counsel WilmerHale

  5. Changing Nature of FTC Orders Agenda • Changes at the Commission • Privacy and Security Orders • Individual Liability • Future of FTC Enforcement and Authority • Questions?

  6. Changes at the FTC

  7. Changes at the Commission New Commissioners Reassessing Priorities • • Joseph Simons Hearings on Competition and • Consumer Protection in the 21 st Noah Phillips • Rohit Chopra Century • • Rebecca Slaughter 14 hearings conducted • Christine Wilson

  8. Privacy and Security Orders

  9. Privacy & Security Orders • Groundbreaking provisions in Orders • Sweeping governance provisions • Requirements for external oversight • Greater accountability at Board and senior officer level • Record‐setting penalties and new injunctive provisions

  10. Individual Liability

  11. Individual Liability • Democratic Commissioners pushing for more individual liability. • Orders requiring annual certifications by senior officers and providing for personal liability for CEO, compliance officers, or directors for false certifications.

  12. Future of FTC Authority and Enforcement

  13. Future Authority and Enforcement • Federal and State Privacy and Data Protection Legislation • Rulemaking Authority • Enforcement Authority and Remedies • Active State Attorneys General

  14. Future Authority and Enforcement • Questions?

  15. Contact Alexis Goltra Reed Freeman Nicole Ewart Vice President, Legal & Partner Counsel Chief Privacy Officer WilmerHale WilmerHale Nicole.Ewart@wilmerhale.com Oracle Reed.Freeman@wilmerhale.com

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