START 

WITH

A GUIDE FOR BUSINESS

FEDERAL TRADE COMMISSION

LESSONS LEARNED FROM FTC CASES

1. Start with security. 

2. Control access to data sensibly.

3. Require secure passwords and authentication.

4. Store sensitive personal information securely and protect it 

during transmission.

5. Segment your network and monitor who’s trying to get in and 

out.

6. Secure remote access to your network.

7. Apply sound security practices when developing new products.

8. Make sure your service providers implement reasonable security 

measures.

9. Put procedures in place to keep your security current and 

address vulnerabilities that may arise.

10. Secure paper, physical media, and devices.

START 

WITH

1

When managing your network, developing an app, or even organizing paper 

files, sound security is no accident. Companies that consider security from the 

start assess their options and make reasonable choices based on the nature 

of their business and the sensitivity of the information involved. Threats to 

data may transform over time, but the fundamentals of sound security remain 

constant. As the Federal Trade Commission outlined in Protecting Personal 

Information: A Guide for Business, you should know what personal information 

you have in your files and on your computers, and keep only what you need 

for your business. You should protect the information that you keep, and 

properly dispose of what you no longer need. And, of course, you should 

create a plan to respond to security incidents.

In addition to Protecting Personal Information, the FTC has resources to help 

you think through how those principles apply to your business. There’s an 

online tutorial to help train your employees; publications to address particular 

data security challenges; and news releases, blog posts, and guidance to help 

you identify – and possibly prevent – pitfalls.

There’s another source of information about keeping sensitive data secure: 

the lessons learned from the more than 50 law enforcement actions the FTC 

has announced so far. These are settlements – no findings have been made 

by a court – and the specifics of the orders apply just to those companies, 

of course. But learning about alleged lapses that led to law enforcement can 

help your company improve its practices. And most of these alleged practices 

involve basic, fundamental security missteps. Distilling the facts of those 

cases down to their essence, here are ten lessons to learn that touch on 

vulnerabilities that could affect your company, along with practical guidance on 

how to reduce the risks they pose.
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Start with security. 

From personal data on employment applications to network files with customers’ credit 

card numbers, sensitive information pervades every part of many companies. Business 

executives often ask how to manage confidential information. Experts agree on the key 

first step: Start with security. Factor it into the decisionmaking in every department of 

your business – personnel, sales, accounting, information technology, etc. Collecting and 

maintaining information “just because” is no longer a sound business strategy. Savvy 

companies think through the implication of their data decisions. By making conscious 

choices about the kind of information you collect, how long you keep it, and who can 

access it, you can reduce the risk of a data compromise down the road. Of course, all 

of those decisions will depend on the nature of your business. Lessons from FTC cases 

illustrate the benefits of building security in from the start by going lean and mean in your 

data collection, retention, and use policies.

Don’t collect personal information you don’t need. 

Here’s a foundational principle to inform your initial decision-making: No one can steal 

what you don’t have. When does your company ask people for sensitive information? 

Perhaps when they’re registering online or setting up a new account. When was the last 

time you looked at that process to make sure you really need everything you ask for? 

That’s the lesson to learn from a number of FTC cases. For example, the FTC’s complaint 

against RockYou charged that the company collected lots of information during the 

site registration process, including the user’s email address and email password. By 

collecting email passwords – not something the business needed – and then storing 

them in clear text, the FTC said the company created an unnecessary risk to people’s 

email accounts. The business could have avoided that risk simply by not collecting 

sensitive information in the first place. 

Hold on to information only as long as you have a legitimate 

business need. 

Sometimes it’s necessary to collect personal data as part of a transaction. But once the 

deal is done, it may be unwise to keep it. In the FTC’s BJ’s Wholesale Club case, the 

company collected customers’ credit and debit card information to process transactions 

in its retail stores. But according to the complaint, it continued to store that data for 

up to 30 days – long after the sale was complete. Not only did that violate bank rules, 

but by holding on to the information without a legitimate business need, the FTC said 

BJ’s Wholesale Club created an unreasonable risk. By exploiting other weaknesses in 

the company’s security practices, hackers stole the account data and used it to make 

counterfeit credit and debit cards. The business could have limited its risk by securely 

disposing of the financial information once it no longer had a legitimate need for it. 

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Don’t use personal information when it’s not necessary.

You wouldn’t juggle with a Ming vase. Nor should businesses use personal information 

in contexts that create unnecessary risks. In the Accretive case, the FTC alleged that the 

company used real people’s personal information in employee training sessions, and 

then failed to remove the information from employees’ computers after the sessions were 

over. Similarly, in foru International, the FTC charged that the company gave access to 

sensitive consumer data to service providers who were developing applications for the 

company. In both cases, the risk could have been avoided by using fictitious information 

for training or development purposes.

Control access to data sensibly.

Once you’ve decided you have a legitimate business need to hold on to sensitive data, 

take reasonable steps to keep it secure. You’ll want to keep it from the prying eyes of 

outsiders, of course, but what about your own employees? Not everyone on your staff 

needs unrestricted access to your network and the information stored on it. Put controls 

in place to make sure employees have access only on a “need to know” basis. For your 

network, consider steps such as separate user accounts to limit access to the places 

where personal data is stored or to control who can use particular databases. For paper 

files, external drives, disks, etc., an access control could be as simple as a locked file 

cabinet. When thinking about how to control access to sensitive information in your 

possession, consider these lessons from FTC cases.

Restrict access to sensitive data.

If employees don’t have to use personal information as part of their job, there’s no need 

for them to have access to it. For example, in Goal Financial, the FTC alleged that the 

company failed to restrict employee access to personal information stored in paper 

files and on its network. As a result, a group of employees transferred more than 7,000 

consumer files containing sensitive information to third parties without authorization. 

The company could have prevented that misstep by implementing proper controls and 

ensuring that only authorized employees with a business need had access to people’s 

personal information. 

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Limit administrative access. 

Administrative access, which allows a user to make system-wide changes to your system, 

should be limited to the employees tasked to do that job. In its action against Twitter, 

for example, the FTC alleged that the company granted almost all of its employees 

administrative control over Twitter’s system, including the ability to reset user account 

passwords, view users’ nonpublic tweets, and send tweets on users’ behalf. According 

to the complaint, by providing administrative access to just about everybody in-house, 

Twitter increased the risk that a compromise of any of its employees’ credentials could 

result in a serious breach. How could the company have reduced that risk? By ensuring 

that employees’ access to the system’s administrative controls was tailored to their job 

needs.

Require secure passwords and 

authentication.

If you have personal information stored on your network, strong authentication 

procedures – including sensible password “hygiene” – can help ensure that only 

authorized individuals can access the data. When developing your company’s policies, 

here are tips to take from FTC cases.

Insist on complex and unique passwords. 

“Passwords” like 121212 or qwerty aren’t much better than no passwords at all. That’s 

why it’s wise to give some thought to the password standards you implement. In the 

Twitter case, for example, the company let employees use common dictionary words 

as administrative passwords, as well as passwords they were already using for other 

accounts. According to the FTC, those lax practices left Twitter’s system vulnerable 

to hackers who used password-guessing tools, or tried passwords stolen from other 

services in the hope that Twitter employees used the same password to access the 

company’s system. Twitter could have limited those risks by implementing a more secure 

password system – for example, by requiring employees to choose complex passwords 

and training them not to use the same or similar passwords for both business and 

personal accounts. 

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Store passwords securely. 

Don’t make it easy for interlopers to access passwords. In Guidance Software, the 

FTC alleged that the company stored network user credentials in clear, readable text 

that helped a hacker access customer credit card information on the network. Similarly, 

in Reed Elsevier, the FTC charged that the business allowed customers to store user 

credentials in a vulnerable format in cookies on their computers. In Twitter, too, the FTC 

said the company failed to establish policies that prohibited employees from storing 

administrative passwords in plain text in personal email accounts. In each of those cases, 

the risks could have been reduced if the companies had policies and procedures in place 

to store credentials securely. Businesses also may want to consider other protections 

– two-factor authentication, for example – that can help protect against password 

compromises. 

Guard against brute force attacks. 

Remember that adage about an infinite number of monkeys at an infinite number of 

typewriters? Hackers use automated programs that perform a similar function. These 

brute force attacks work by typing endless combinations of characters until hackers luck 

into someone’s password. In the Lookout Services, Twitter, and Reed Elsevier cases, the 

FTC alleged that the businesses didn’t suspend or disable user credentials after a certain 

number of unsuccessful login attempts. By not adequately restricting the number of tries, 

the companies placed their networks at risk. Implementing a policy to suspend or disable 

accounts after repeated login attempts would have helped to eliminate that risk. 

Protect against authentication bypass. 

Locking the front door doesn’t offer much protection if the back door is left open. In 

Lookout Services, the FTC charged that the company failed to adequately test its 

web application for widely-known security flaws, including one called “predictable 

resource location.” As a result, a hacker could easily predict patterns and manipulate 

URLs to bypass the web app’s authentication screen and gain unauthorized access 

to the company’s databases. The company could have improved the security of its 

authentication mechanism by testing for common vulnerabilities.
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Store sensitive personal information 

securely and protect it during transmission.

For many companies, storing sensitive data is a business necessity. And even if you 

take appropriate steps to secure your network, sometimes you have to send that data 

elsewhere. Use strong cryptography to secure confidential material during storage 

and transmission. The method will depend on the types of information your business 

collects, how you collect it, and how you process it. Given the nature of your business, 

some possibilities may include Transport Layer Security/Secure Sockets Layer (TLS/SSL) 

encryption, data-at-rest encryption, or an iterative cryptographic hash. But regardless of 

the method, it’s only as good as the personnel who implement it. Make sure the people 

you designate to do that job understand how your company uses sensitive data and have 

the know-how to determine what’s appropriate for each situation. With that in mind, here 

are a few lessons from FTC cases to consider when securing sensitive information during 

storage and transmission.

Keep sensitive information secure throughout its lifecycle. 

Data doesn’t stay in one place. That’s why it’s important to consider security at all 

stages, if transmitting information is a necessity for your business. In Superior Mortgage 

Corporation, for example, the FTC alleged that the company used SSL encryption to 

secure the transmission of sensitive personal information between the customer’s web 

browser and the business’s website server. But once the information reached the server, 

the company’s service provider decrypted it and emailed it in clear, readable text to 

the company’s headquarters and branch offices. That risk could have been prevented 

by ensuring the data was secure throughout its lifecycle, and not just during the initial 

transmission. 

Use industry-tested and accepted methods. 

When considering what technical standards to follow, keep in mind that experts already 

may have developed effective standards that can apply to your business. Savvy 

companies don’t start from scratch when it isn’t necessary. Instead, they take advantage 

of that collected wisdom. The ValueClick case illustrates that principle. According 

to the FTC, the company stored sensitive customer information collected through its 

e-commerce sites in a database that used a non-standard, proprietary form of encryption. 

Unlike widely-accepted encryption algorithms that are extensively tested, the complaint 

charged that ValueClick’s method used a simple alphabetic substitution system subject to 

significant vulnerabilities. The company could have avoided those weaknesses by using 

tried-and-true industry-tested and accepted methods for securing data. 

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Ensure proper configuration. 

Encryption – even strong methods – won’t protect your users if you don’t configure 

it properly. That’s one message businesses can take from the FTC’s actions against 

Fandango and Credit Karma. In those cases, the FTC alleged that the companies 

used SSL encryption in their mobile apps, but turned off a critical process known as 

SSL certificate validation without implementing other compensating security measures. 

That made the apps vulnerable to man-in-the-middle attacks, which could allow hackers 

to decrypt sensitive information the apps transmitted. Those risks could have been 

prevented if the companies’ implementations of SSL had been properly configured.

Segment your network and monitor who’s 

trying to get in and out.

When designing your network, consider using tools like firewalls to segment your 

network, thereby limiting access between computers on your network and between your 

computers and the internet. Another useful safeguard: intrusion detection and prevention 

tools to monitor your network for malicious activity. Here are some lessons from FTC 

cases to consider when designing your network.

Segment your network. 

Not every computer in your system needs to be able to communicate with every other 

one. You can help protect particularly sensitive data by housing it in a separate secure 

place on your network. That’s a lesson from the DSW case. The FTC alleged that the 

company didn’t sufficiently limit computers from one in-store network from connecting 

to computers on other in-store and corporate networks. As a result, hackers could use 

one in-store network to connect to, and access personal information on, other in-store 

and corporate networks. The company could have reduced that risk by sufficiently 

segmenting its network.

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Monitor activity on your network. 

“Who’s that knocking on my door?” That’s what an effective intrusion detection tool asks 

when it detects unauthorized activity on your network. In the Dave & Buster’s case, 

the FTC alleged that the company didn’t use an intrusion detection system and didn’t 

monitor system logs for suspicious activity. The FTC says something similar happened 

in Cardsystem Solutions. The business didn’t use sufficient measures to detect 

unauthorized access to its network. Hackers exploited weaknesses, installing programs 

on the company’s network that collected stored sensitive data and sent it outside the 

network every four days. In each of these cases, the businesses could have reduced 

the risk of a data compromise or its breadth by using tools to monitor activity on their 

networks. 

Secure remote access to your network.

Business doesn’t just happen in the office. While a mobile workforce can increase 

productivity, it also can pose new security challenges. If you give employees, clients, 

or service providers remote access to your network, have you taken steps to secure 

those access points? FTC cases suggest some factors to consider when developing your 

remote access policies.

Ensure endpoint security. 

Just as a chain is only as strong as its weakest link, your network security is only as 

strong as the weakest security on a computer with remote access to it. That’s the 

message of FTC cases in which companies failed to ensure that computers with remote 

access to their networks had appropriate endpoint security. For example, in Premier 

Capital Lending, the company allegedly activated a remote login account for a business 

client to obtain consumer reports, without first assessing the business’s security. When 

hackers accessed the client’s system, they stole its remote login credentials and used 

them to grab consumers’ personal information. According to the complaint in Settlement 

One, the business allowed clients that didn’t have basic security measures, like firewalls 

and updated antivirus software, to access consumer reports through its online portal. 

And in Lifelock, the FTC charged that the company failed to install antivirus programs on 

the computers that employees used to remotely access its network. These businesses 

could have reduced those risks by securing computers that had remote access to their 

networks. 

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Put sensible access limits in place. 

Not everyone who might occasionally need to get on your network should have an allaccess, backstage pass. That’s why it’s wise to limit access to what’s needed to get the 

job done. In the Dave & Buster’s case, for example, the FTC charged that the company 

failed to adequately restrict third-party access to its network. By exploiting security 

weaknesses in the third-party company’s system, an intruder allegedly connected to the 

network numerous times and intercepted personal information. What could the company 

have done to reduce that risk? It could have placed limits on third-party access to its 

network – for example, by restricting connections to specified IP addresses or granting 

temporary, limited access.

Apply sound security practices when 

developing new products.

So you have a great new app or innovative software on the drawing board. Early in the 

development process, think through how customers will likely use the product. If they’ll 

be storing or sending sensitive information, is your product up to the task of handling that 

data securely? Before going to market, consider the lessons from FTC cases involving 

product development, design, testing, and roll-out.

Train your engineers in secure coding. 

Have you explained to your developers the need to keep security at the forefront? In 

cases like MTS, HTC America, and TRENDnet, the FTC alleged that the companies failed 

to train their employees in secure coding practices. The upshot: questionable design 

decisions, including the introduction of vulnerabilities into the software. For example, 

according to the complaint in HTC America, the company failed to implement readily 

available secure communications mechanisms in the logging applications it pre-installed 

on its mobile devices. As a result, malicious third-party apps could communicate with 

the logging applications, placing consumers’ text messages, location data, and other 

sensitive information at risk. The company could have reduced the risk of vulnerabilities 

like that by adequately training its engineers in secure coding practices. 

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Follow platform guidelines for security. 

When it comes to security, there may not be a need to reinvent the wheel. Sometimes 

the wisest course is to listen to the experts. In actions against HTC America, Fandango, 

and Credit Karma, the FTC alleged that the companies failed to follow explicit platform 

guidelines about secure development practices. For example, Fandango and Credit 

Karma turned off a critical process known as SSL certificate validation in their mobile 

apps, leaving the sensitive information consumers transmitted through those apps open 

to interception through man-in-the-middle attacks. The companies could have prevented 

this vulnerability by following the iOS and Android guidelines for developers, which 

explicitly warn against turning off SSL certificate validation. 

Verify that privacy and security features work. 

If your software offers a privacy or security feature, verify that the feature works as 

advertised. In TRENDnet, for example, the FTC charged that the company failed to test 

that an option to make a consumer’s camera feed private would, in fact, restrict access 

to that feed. As a result, hundreds of “private” camera feeds were publicly available. 

Similarly, in Snapchat, the company advertised that messages would “disappear forever,” 

but the FTC says it failed to ensure the accuracy of that claim. Among other things, 

the app saved video files to a location outside of the app’s sandbox, making it easy to 

recover the video files with common file browsing tools. The lesson for other companies: 

When offering privacy and security features, ensure that your product lives up to your 

advertising claims.

Test for common vulnerabilities. 

There is no way to anticipate every threat, but some vulnerabilities are commonly 

known and reasonably foreseeable. In more than a dozen FTC cases, businesses failed 

to adequately assess their applications for well-known vulnerabilities. For example, in 

the Guess? case, the FTC alleged that the business failed to assess whether its web 

application was vulnerable to Structured Query Language (SQL) injection attacks. 

As a result, hackers were able to use SQL attacks to gain access to databases with 

consumers’ credit card information. That’s a risk that could have been avoided by testing 

for commonly-known vulnerabilities, like those identified by the Open Web Application 

Security Project (OWASP).
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Make sure your service providers 

implement reasonable security measures.

When it comes to security, keep a watchful eye on your service providers – for example, 

companies you hire to process personal information collected from customers or to 

develop apps. Before hiring someone, be candid about your security expectations. Take 

reasonable steps to select providers able to implement appropriate security measures 

and monitor that they’re meeting your requirements. FTC cases offer advice on what to 

consider when hiring and overseeing service providers.

Put it in writing.

Insist that appropriate security standards are part of your contracts. In GMR 

Transcription, for example, the FTC alleged that the company hired service providers 

to transcribe sensitive audio files, but failed to require the service provider to take 

reasonable security measures. As a result, the files – many containing highly confidential 

health-related information – were widely exposed on the internet. For starters, the 

business could have included contract provisions that required service providers to 

adopt reasonable security precautions – for example, encryption.

Verify compliance.

Security can’t be a “take our word for it” thing. Including security expectations in 

contracts with service providers is an important first step, but it’s also important to build 

oversight into the process. The Upromise case illustrates that point. There, the company 

hired a service provider to develop a browser toolbar. Upromise claimed that the toolbar, 

which collected consumers’ browsing information to provide personalized offers, would 

use a filter to “remove any personally identifiable information” before transmission. 

But, according to the FTC, Upromise failed to verify that the service provider had 

implemented the information collection program in a manner consistent with Upromise’s 

privacy and security policies and the terms in the contract designed to protect consumer 

information. As a result, the toolbar collected sensitive personal information – including 

financial account numbers and security codes from secure web pages – and transmitted 

it in clear text. How could the company have reduced that risk? By asking questions and 

following up with the service provider during the development process.

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Put procedures in place to keep your 

security current and address vulnerabilities 

that may arise.

Securing your software and networks isn’t a one-and-done deal. It’s an ongoing process 

that requires you to keep your guard up. If you use third-party software on your networks, 

or you include third-party software libraries in your applications, apply updates as they’re 

issued. If you develop your own software, how will people let you know if they spot a 

vulnerability, and how will you make things right? FTC cases offer points to consider in 

thinking through vulnerability management.

Update and patch third-party software. 

Outdated software undermines security. The solution is to update it regularly and 

implement third-party patches. In the TJX Companies case, for example, the FTC alleged 

that the company didn’t update its anti-virus software, increasing the risk that hackers 

could exploit known vulnerabilities or overcome the business’s defenses. Depending 

on the complexity of your network or software, you may need to prioritize patches by 

severity; nonetheless, having a reasonable process in place to update and patch thirdparty software is an important step to reducing the risk of a compromise.

Heed credible security warnings and move quickly to fix them. 

When vulnerabilities come to your attention, listen carefully and then get a move on. In 

the HTC America case, the FTC charged that the company didn’t have a process for 

receiving and addressing reports about security vulnerabilities. HTC’s alleged delay in 

responding to warnings meant that the vulnerabilities found their way onto even more 

devices across multiple operating system versions. Sometimes, companies receive 

security alerts, but they get lost in the shuffle. In Fandango, for example, the company 

relied on its general customer service system to respond to warnings about security 

risks. According to the complaint, when a researcher contacted the business about a 

vulnerability, the system incorrectly categorized the report as a password reset request, 

sent an automated response, and marked the message as “resolved” without flagging 

it for further review. As a result, Fandango didn’t learn about the vulnerability until 

FTC staff contacted the company. The lesson for other businesses? Have an effective 

process in place to receive and address security vulnerability reports. Consider a 

clearly publicized and effective channel (for example, a dedicated email address like 

security@yourcompany.com) for receiving reports and flagging them for your security 

staff.

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Secure paper, physical media, and devices.

Network security is a critical consideration, but many of the same lessons apply to 

paperwork and physical media like hard drives, laptops, flash drives, and disks. FTC 

cases offer some things to consider when evaluating physical security at your business. 

Securely store sensitive files. 

If it’s necessary to retain important paperwork, take steps to keep it secure. In the 

Gregory Navone case, the FTC alleged that the defendant maintained sensitive 

consumer information, collected by his former businesses, in boxes in his garage. In 

Lifelock, the complaint charged that the company left faxed documents that included 

consumers’ personal information in an open and easily accessible area. In each case, 

the business could have reduced the risk to their customers by implementing policies to 

store documents securely.

Protect devices that process personal information. 

Securing information stored on your network won’t protect your customers if the data 

has already been stolen through the device that collects it. In the 2007 Dollar Tree

investigation, FTC staff said that the business’s PIN entry devices were vulnerable 

to tampering and theft. As a result, unauthorized persons could capture consumer’s 

payment card data, including the magnetic stripe data and PIN, through an attack known 

as “PED skimming.” Given the novelty of this type of attack at the time, and a number 

of other factors, staff closed the investigation. However, attacks targeting point-of-sale 

devices are now common and well-known, and businesses should take reasonable steps 

to protect such devices from compromise.

Keep safety standards in place when data is en route. 

Savvy businesses understand the importance of securing sensitive information when 

it’s outside the office. In Accretive, for example, the FTC alleged that an employee left 

a laptop containing more than 600 files, with 20 million pieces of information related to 

23,000 patients, in the locked passenger compartment of a car, which was then stolen. 

The CBR Systems case concerned alleged unencrypted backup tapes, a laptop, and an 

external hard drive – all of which contained sensitive information – that were lifted from 

an employee’s car. In each case, the business could have reduced the risk to consumers’ 

personal information by implementing reasonable security policies when data is en route. 

For example, when sending files, drives, disks, etc., use a mailing method that lets you 

track where the package is. Limit the instances when employees need to be out and 

about with sensitive data in their possession. But when there’s a legitimate business 

need to travel with confidential information, employees should keep it out of sight and 

under lock and key whenever possible. 

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Looking for more information?

The FTC’s Business Center (business.ftc.gov) has a Data Security section with 

an up-to-date listing of relevant cases and other free resources. 

About the FTC

The FTC works for the consumer to prevent fraudulent, deceptive, and 

unfair practices in the marketplace. The Business Center gives you and your 

business tools to understand and comply with the law. Regardless of the size 

of your organization or the industry you’re in, knowing – and fulfilling – your 

compliance responsibilities is smart, sound business. Visit the Business Center 

at business.ftc.gov.

Your Opportunity to Comment

The National Small Business Ombudsman and 10 Regional Fairness Boards 

collect comments from small businesses about federal compliance and 

enforcement activities. Each year, the Ombudsman evaluates the conduct of 

these activities and rates each agency’s responsiveness to small businesses. 

Small businesses can comment to the Ombudsman without fear of reprisal. 

To comment, call toll-free 1-888-REGFAIR (1-888-734-3247) or go to

sba.gov/ombudsman.

Dispose of sensitive data securely. 

Paperwork or equipment you no longer need may look like trash, but it’s treasure to 

identity thieves if it includes personal information about consumers or employees. 

For example, according to the FTC complaints in Rite Aid and CVS Caremark, the 

companies tossed sensitive personal information – like prescriptions – in dumpsters. 

In Goal Financial, the FTC alleged that an employee sold surplus hard drives that 

contained the sensitive personal information of approximately 34,000 customers in clear 

text. The companies could have prevented the risk to consumers’ personal information 

by shredding, burning, or pulverizing documents to make them unreadable and by using 

available technology to wipe devices that aren’t in use.

Federal Trade Commission

business.ftc.gov

June 2015