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Consent DecreeLow Risk

FTC Orders Chegg to Strengthen Student Data Security

Chegg Inc.January 27, 2023Federal Trade Commission

Consumers Affected

40,000,000

Summary

The FTC finalized an order against Chegg Inc. for failing to secure student data, leading to breaches that exposed personal information of about 40 million users and employees. Chegg must implement a comprehensive security program, limit data collection, offer multifactor authentication, and allow data access and deletion.

Remedy

Chegg is required to implement a comprehensive information security program, limit the data it collects and retains, provide multifactor authentication to users, and allow users to request access to and deletion of their data.

Compliance ProgramData Deletion

Contract Impact

In-house legal teams should review all vendor and customer agreements, particularly those with educational institutions or directly with students/parents, for clauses governing data security, breach notification, data minimization, and user rights. Specific clauses to scrutinize include data security requirements, encryption standards, password management, data retention and deletion policies, and provisions allowing user access or deletion requests. Given the order's focus on limiting data collection and offering multifactor authentication, contracts may need amendments to mandate MFA for account access, impose stricter data collection and retention limits, require robust encryption (including for stored data and passwords), and establish clear processes for user data access and deletion requests. Employment agreements handling employee personal and medical information should also be reviewed for adequate data protection safeguards.

Contract Search Terms

data security programmultifactor authenticationdata retention limitsdata access rightsdata deletion rightsencryption standardsbreach notification clausesensitive data handlingstudent data protectionpassword security

Violation Types

Entity Details

Entity

Chegg Inc.

Also known as: Chegg

Industry

Education

Official Sources

Source Evidence

Entity Name
"Chegg Inc."
Violation Types
"careless data security practices"
Violation Types
"Exposed Student Data"
Violation Types
"medical information about Chegg employees"
Consumers Affected
"about 40 million users and employees"

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