FTC to Companies: Do Not Fib About Your Participation in EU-U.S. Privacy Shield


  • The Federal Trade Commission (“FTC”) reached a settlement with digital clinical trial company Medable, Inc. to resolve allegations that it misled consumers about its participation in and compliance with the EU-U.S. Privacy Shield framework (“Privacy Shield”) in violation of the FTC Act.
  • According to the FTC’s complaint, Medable allegedly claimed that it participated in Privacy Shield even though it was never certified as a participant.
  • Under the terms of the order, Medable is precluded from misrepresenting its participation in Privacy Shield or any other data privacy or security program sponsored by the government or any other standard-setting organization, and is required to periodically report on its compliance with the order to the FTC, among other things.