The U.S. Federal Trade Commission's privacy and data security rulemaking proposal could prove to be a lofty undertaking despite some advanced planning. IAPP Westin Emeritus Fellow and Goodwin Procter Partner Omer Tene said the broad nature of the agency's recently issued Advance Notice of Proposed Rulemaking brings part risk and opportunity. Tene explains the potential ups and downs of the rulemaking proposal while suggesting ideas to "rein in the process and focus on results that are attainable."
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