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FTC Settles with Zoom Over Security Misrepresentations and Bypass Practices

Zoom Video Communications, Inc.November 9, 2020Federal Trade Commission

Summary

The FTC settled with Zoom for deceiving users about its encryption security and unfairly installing software that bypassed browser safeguards. Zoom must implement a comprehensive security program, undergo biennial audits, and is banned from making false security claims. No monetary penalty was imposed.

Remedy

Zoom must establish and implement a comprehensive information security program with annual risk assessments, vulnerability management, multi-factor authentication, and data deletion controls. It is prohibited from making misrepresentations about privacy and security. The company must undergo biennial third-party security audits and notify the FTC of any data breaches.

Compliance ProgramInjunctionAudit RequirementReporting Requirements

Contract Impact

In-house legal teams should review vendor, customer, and data processing agreements for clauses related to security representations, encryption standards, and software installation. Specifically, examine any warranties or descriptions of security features (e.g., 'end-to-end encryption'), terms governing the installation of additional software or plugins, and provisions requiring compliance with specific security programs or audits. Given the FTC's findings, agreements may need amendments to ensure all security claims are accurate and non-misleading, incorporate requirements for a comprehensive security program akin to Zoom's mandated program, and include explicit user consent mechanisms for any software that interacts with or bypasses browser safeguards. Additionally, audit rights and reporting obligations should be strengthened to align with the biennial audit requirement.

Contract Search Terms

end-to-end encryptionbrowser security featuresoftware installation consentsecurity audit requirementsfalse security claimscomprehensive security programdata security representationsuser consent for softwareencryption misrepresentationsbypass security safeguards

Laws Cited

FTC Act

Violation Types

Entity Details

Entity

Zoom Video Communications, Inc.

Also known as: Zoom

Industry

Technology

Official Sources

Source Evidence

Entity Name
"Zoom Video Communications, Inc."
Laws Cited
"FTC Act"
Violation Types
"misled users by touting that it offered “end-to-end, 256-bit encryption”"
Violation Types
"secretly installed software, called a ZoomOpener web server"

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