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FTC Orders Ascension Data & Analytics to Strengthen Vendor Security Under GLBA

Ascension Data & Analytics, LLCDecember 22, 2021Federal Trade Commission

Summary

The FTC settled with Ascension Data & Analytics, LLC for violating the Gramm-Leach-Bliley Act's Safeguards Rule by failing to ensure its vendor properly protected consumer data. The company must strengthen its security safeguards and increase oversight of vendors. No monetary penalty was imposed.

Remedy

The company is required to implement and maintain a comprehensive information security program, ensure third-party vendors have adequate safeguards, and increase oversight of vendors.

InjunctionCompliance ProgramAudit Requirement

Contract Impact

In-house legal teams should review all vendor and data processing agreements, particularly those involving financial or consumer data. Focus on clauses addressing data security standards, third-party vendor oversight, compliance with the Gramm-Leach-Bliley Act (GLBA) Safeguards Rule, encryption requirements, access controls, regular risk assessments, audit rights, and breach notification procedures. Changes may be needed to mandate that vendors implement specific security measures (e.g., encryption, password protection), require annual security audits or certifications of GLBA compliance, include indemnification for data breaches, and grant termination rights for non-compliance with security obligations.

Contract Search Terms

vendor management clausedata security requirementsSafeguards Rule compliancethird-party oversight provisionsinformation security programencryption standardsaccess controlsrisk assessmentdata processing addendumbreach notification

Laws Cited

Gramm-Leach-Bliley Act

Violation Types

Entity Details

Entity

Ascension Data & Analytics, LLC

Also known as: Ascension Data & Analytics

Industry

Financial Services

Official Sources

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