FTC Act § 5
15 U.S.C. § 45Federal Trade Commission Act, Section 5 — unfair or deceptive acts or practices
In force since September 26, 1914
Who it applies to
- Persons, partnerships and corporations engaged in commerce
- In practice the general-purpose privacy and data-security authority in the United States
Consumer rights
- Access / know — not granted
- Correction — not granted
- Deletion / erasure — not granted
- Portability — not granted
- Opt out of sale / sharing — not granted
- Opt out of targeted advertising — not granted
- Opt out of profiling — not granted
- Limit sensitive data use — not granted
- Human review of automated decisions — not granted
- Non-discrimination — not granted
- Appeal a refusal — not granted
- Private right of action — not granted
Obligations
- Consent model
- Mixed
- Universal opt-out signal
- Not required
- Risk assessments
- Not required
- Data protection officer
- Not required
- Records of processing
- Not required
- Processor contract
- Not required
- Right to cure
- None — enforcement may follow immediately
- Data broker registration
- Not required
Breach notification
- To individuals
- Not addressed by this section
- To the regulator
- Not required by this law
- What triggers it
- Not addressed by this section
Penalties
- Headline
- Injunctive relief and consent orders; civil penalties for violating an existing order
- Private right of action
- No — enforcement is by the regulator only
- Notes
- Section 5 creates no rights a consumer can assert directly. It matters because a privacy policy that misstates a practice becomes a deceptive act, which is how most US privacy enforcement actually happens.
Exemptions
Entities
- Banks, savings and loan institutions and federal credit unions
- Common carriers subject to the Communications Act
- Non-profit organisations not operating for their members' profit
Sources
- PrimaryStatute15 U.S.C. § 45 — Unfair methods of competition
- PrimaryEnforcementFTC — cases and proceedings