Summary of Privacy and Data Security Bills- 112 th Congress. Prepared for September 15, 2011 CT Privacy Forum

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1 Summary of Privacy and Data Security Bills- 112 th Congress Prepared for September 15, 2011 CT Privacy Forum GEOLOCATION TRACKING The Location Privacy Protection Act of 2011 (S. 1223)- introduced by s Sens. Franken (D-MN) Blumenthal (D-CT) and referred to the Senate Judiciary Committee. Would close current loopholes in federal law (ie, ECPA) to require any company that may obtain a customer s location information from his or her smartphone or other mobile device to: o get that customer s express consent before collecting his or her location; and o get that customer s express consent before sharing his or her location data with third parties. The bill also calls upon the National Institute of Justice to issue a study on the use of location technology in dating violence, stalking and domestic violence and would facilitate the reporting of these crimes to IC3. Would have the Attorney General to develop a training curriculum so that law enforcement, courts, and victims advocates can better investigate and prosecute crimes involving the misuse of geo-location data. Would create criminal liability abusers of location technology for so-called stalking apps that knowingly and intentionally disclose geolocation information while knowing and intending that domestic violence or stalking will occur as a result of this disclosure; Would also criminalize the knowing and intentional aggregation and sale of the location data of children 10 years old and younger. Authorizes civil actions by the Attorney General. State AG enforcement in Dist. Court. Private right of action. PERSONAL DATA SECURITY/DATA BREACH NOTIFICAITON Personal Data Privacy and Security Act of 2011 (S. 1151)- introduced by Sen. Leahy (D-VT) and referred to the Senate Judiciary Committee. State AG enforcement concurrent with FTC (mimics HITECH); $5k per day; $500,000 cap per violation. No private cause of action. Requires business entities that involved in collecting, accessing, transmitting, using, storing, or disposing of sensitive personally identifiable information comply with a data security program to safeguard sensitive personal data. Would make the concealment of security breaches involving sensitive personally identifiable information a crime with penalties of a fine or imprisonment for not more than five years.

2 Requires any agency or business entity that uses sensitive personally identifiable information, following the discovery of a security breach of such information, notify any resident of the United States whose sensitive personally identifiable information has been, or is reasonably believed to have been, accessed or acquired. The business entity or agency must notify the United States Secret Service and the FBI of the fact that a security breach has occurred if the number of the individuals affected by the breach exceeds 10,000, if the security breach involves a database containing the sensitive personally identifiable information of more than 1,000,000 individuals nationwide, if the security breach involves databases owned by the federal government, or if the security breach involves sensitive personally identifiable information of employees and contractors of the federal government involved in national security or law enforcement. Personal Data Protection and Breach Accountability Act of 2011 (S.1535) was introduced by Sen. Blumenthal (D-CT) and referred to the Senate Judiciary Committee. State AG enforcement just like Leahy Bill (S.1151), but increases penalties to $5k per violation per day up to total cap of $20,000,000 per violation. Tracks the basic structure of the S.1151 with a few key differences, including: o Includes a private right of action for victims of data breaches who incur actual damages to hold companies accountable for not complying with the minimum protection and/or notification standards laid out in the Act. o Making it a crime to send out fake data breach notifications in an attempt to obtain personally identifiable information from consumers. o Making it a crime for a person who is not an authorized user of a computer to install unauthorized spyware software that collects sensitive personally identifiable information from an authorized user or redirects web search requests without the knowledge or consent of the consumer, with certain exceptions. o Requires businesses and agencies to provide victims of a security breach, upon request, with mandatory remedies including two years of credit monitoring, a security freeze, and restitution for the costs incurred as a result of the breach. These remedies would mitigate the actual harms that could stem from a security breach. o Expands required notification methods to also require notification to consumers via commonly used electronic interfaces, such as an ATM terminal, a business s homepage, or a website s login screen. o Facilitates information sharing between the government and the private sector by allowing the Attorney General to maintain a clearinghouse of technical information concerning system vulnerabilities identified and inform the private sector of threats and effective preventative measures to help prevent future breaches. Data Security and Breach Notification Act of 2011 (S. 1207) was introduced by Sen. Pryor (D- AR) and referred to the Senate Committee on Commerce, Science, and Transportation. FTC and State AG enforcement but preemption of state information security practices and breach notification laws; carve out for consumer protection laws. Penalties capped at $5k per violation and $5,000,000 cap for each of the two sections (information security and breach notification).

3 Would require businesses and nonprofit organizations that store consumers personal information to put in place, and report to the FTC, security policies to safeguard sensitive data and to alert consumers when this data has been breached. Affected consumers would be entitled to receive consumer credit reports or credit monitoring services for two years. Makes it unlawful for information brokers to obtain or disclose personal information by false pretenses. Data Security Act of 2011 (S.1434) was introduced by Sen. Carper (D-DE) and referred to the Senate Banking, Housing and Urban Affairs Committee. Complete preemption of any state law relating to any act or practice governed under this act; and no civil or criminal action in state court permitted. Prescribes security procedures which a business entity that maintains or communicates sensitive account or personal information must implement and enforce in order to protect the information from unauthorized use. Grants exclusive enforcement powers to specified federal regulatory agencies with oversight of financial institutions. No private right of action, including a class action. Data Accountability and Trust Act (H.R. 1707) was introduced by Rep. Rush (D-IL) and referred to the House Commerce, Manufacturing and Trade Subcommittee. Preemption of stat information security laws, carve out for CP laws. State AG enforcement of this act; penalties track Pryor s S Would require the Federal Trade Commission (FTC) to promulgate regulations requiring each person engaged in interstate commerce that owns or possesses data containing personal information to establish specified security policies and procedures to treat and protect such information. Requires information brokers to submit their security policies to the FTC in conjunction with a notification of a security breach notification or on FTC request. Directs the FTC to require information brokers to establish measures which facilitate the auditing or retracing of access to, or transmissions of, any data containing personal information. Provides for nationwide notice in the event of a security breach, requiring notice to the individuals affected by the breach and to the FTC. SAFE Data Act (H.R. 2577) was introduced by Rep. Bono Mack (R-CA) and referred to the House Subcommittee Commerce, Manufacturing, and Trade. State AG enforcement of the act; penalties track Pryor s S Preemption of state information security and breach laws; carve out for CP laws. Would require any person engaged in interstate commerce that owns or possesses data containing personal information, including an information broker and any third party that has contracted with such person to maintain or process such data, to establish and implement reasonable policies and procedures regarding information security practices for the protection of personal information

4 Requires in the event of a breach of security that any person engaged in interstate commerce that owns or possesses data in electronic form containing personal information notify appropriate federal law enforcement officials and each consumer whose information was affected by the breach. CYBERSECURITY Executive Cyberspace Coordination Act of 2011 (H.R. 1136) was introduced by Rep. Langevin (D-RI) and referred to the House Homeland Security Committee. Would establish in the Executive Office of the President the National Office for Cyberspace to serve as the principal office for coordinating issues relating to cyberspace. Establishes within such this office the Federal Cybersecurity Practice Board to be responsible for developing and updating information security policies and procedures. Prohibits any agency from entering into a contract, an order under a contract, or an interagency agreement for information technology without including requirements for effective information security that supports the operations and assets of that agency. Cybersecurity and Internet Freedom Act of 2011 (S. 413) was introduced by Senator Lieberman (ID-CT) and referred to the Committee on Homeland Security and Governmental Affairs. Declares that neither the President, the Director of the National Center for Cybersecurity and Communications, nor any officer or employee of the U.S. government shall have the authority to shut down the Internet. Establishes in the Executive Office of the President an Office of Cyberspace Policy, which shall: (1) develop a national strategy to increase the security and resiliency of cyberspace; (2) oversee, coordinate, and integrate federal policies and activities relating to cyberspace security and resiliency; (3) ensure that all federal agencies comply with appropriate guidelines, policies, and directives from the Department of Homeland Security (DHS), other federal agencies with responsibilities relating to cyberspace security or resiliency, and the National Center for Cybersecurity and Communications (established by this Act); and (4) ensure that federal agencies have access to, receive, and appropriately disseminate law enforcement, intelligence, terrorism, and any other information relevant to the security of specified federal, military, and intelligence information infrastructure. GENEREAL ONLINE PRIVACY LEGISLATION

5 Commercial Privacy Bill of Rights Act of 2011 (S. 799) was introduced by Sen. Kerry (D-MA) and referred to the Senate Commerce, Science, and Technology Committee. Would establish rights to protect every American when it comes to the collection, use, and dissemination of their personally identifiable information. Collectors of personally identifiable information would be required to implement security measures to protect the information they collect and maintain. Collectors of information must provide clear notice to individuals on the collection practices and the purpose for such collection, and the collector must provide the ability for an individual to opt-out of any information collection that is unauthorized by this bill. Collectors of information would be required to collect only as much information as necessary to process or enforce a transaction or deliver a service, and to retain it for only a reasonable period of time. State AG enforcement authority concurrent with FTC to enforce the act- but no simultaneous enforcement by both SAG and FTC (like HITECH). No private rights of action. Consumer Privacy Protection Act of 2011 (H.R. 1528)- introduced by Reps. Stearns (R-FL) and Matheson (D-UT) and referred to Subcommittee on Commerce, Manufacturing, and Trade. Complete preemption of all state laws and actions to enforce the act. Requires covered entities to notify consumers that their personally identifiable information as defined in the bill may be used for a purpose unrelated to the transaction. Requires entities to notify consumers of any material change in their privacy policy. Requires covered entities to establish a privacy policy with respect to the collection, sale, disclosure for consideration, or use of the consumer's information and such policy be made easily available for consumers. Requires an entity to provide consumers the opportunity to preclude the sale or disclosure of their information to any organization that is not an information-sharing partner. Provides for an FTC approved five-year self-regulatory program and prescribes requirements for a self-regulatory consumer dispute resolution process. Requires the FTC to presume that an entity is in compliance with this act if it participates in an approved self-regulatory program. No private right of action. 1\888\

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