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FTC Settles Privacy Shield Case with NTT Global Data Centers

NTT Global Data Centers, Inc.April 16, 2020Federal Trade Commission

Summary

NTT Global Data Centers settled FTC allegations that it misled consumers about its participation in the EU-U.S. Privacy Shield framework and failed to comply with its requirements. The settlement requires the company to hire a third-party assessor if it re-certifies, prohibits misrepresentations about privacy programs, and mandates continued application of Privacy Shield protections or deletion of data collected while participating.

Remedy

The company must hire a third-party assessor to verify adherence to Privacy Shield promises if it re-certifies, is prohibited from misrepresenting its participation in privacy programs, and must continue to apply Privacy Shield protections to personal information collected while participating or return or delete such information.

Audit RequirementInjunctionData Deletion

Contract Impact

In-house legal teams should review all vendor, customer, and data processing agreements that involve the transfer of personal data from the European Union to the United States. Specifically, scrutinize clauses referencing data transfer mechanisms (like Privacy Shield or its successors), representations regarding participation in or compliance with international privacy frameworks, and obligations that survive the termination or lapse of a certification. Agreements may need amendments to: (1) ensure accurate and non-misleading descriptions of any privacy program participation; (2) incorporate requirements for third-party verification/assessment if the company intends to recertify under a framework like Privacy Shield; and (3) explicitly address the handling or deletion of data collected during a period of prior participation, in line with continuing obligations.

Contract Search Terms

Privacy Shield certificationdata transfer clausethird-party assessor requirementEU-U.S. data transferscertification lapse provisionscontinuing obligationsprivacy policy representationsmarketing materials compliancedata deletion protocolsrecertification conditions

Violation Types

Entity Details

Entity

NTT Global Data Centers, Inc.

Also known as: NTT Global Data Centers

Industry

Technology

Official Sources

Source Evidence

Entity Name
"NTT Global Data Centers, Inc., formerly known as RagingWire Data Centers, Inc. (RagingWire)"
Violation Types
"misled consumers about its participation in the EU-U.S. Privacy Shield framework and failed to adhere to the program’s requirements"

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