Jumpstart Your Cybersecurity Program: Compliance and Best Practices under the FTC’s “Start with Security” Initiative

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On June 30, 2015, the Federal Trade Commission released its “Start with Security” initiative and guidance document aimed towards helping businesses protect their consumers’ information in a world where sensitive data is often at risk.  The initiative provides 10 steps for small- to medium-sized businesses, developed from lessons learned from 54 FTC data security cases.

Large businesses will benefit from obtaining a proper understanding of the initiative as much as small- or medium-sized businesses.  The increased public exposure of large corporations leads to an increased risk of cyberattacks, even when a cybersecurity program is in place.  In this program, practitioners will obtain an understanding of what the government expects from businesses by examining the enforcement actions that led to the creation of these guidelines.  In some cases, corporations were found liable for multi-million dollar damages due to third party actions.  Practitioners will learn how to effectively tailor a corporation’s security approach to align with the FTC recommendations to not only foster good data security practices to mitigate the risk of data breaches but also to limit liability in the event of a breach.

Building on guidance from the FTC, certified information privacy professionals (CIPPs) from Pepper Hamilton, who regularly counsel various clients on privacy issues, will provide a framework for large businesses to ensure they are fulfilling their company’s legal obligations to protect consumer information.


Educational Objectives:
Program attendees can expect to learn:
• The basis of the enforcement actions that led to the development of the FTC’s 10 steps.
• What constitutes best data security practices.
• How to create successful “best practices” in their own privacy and data security practices.

Who would benefit most from attending this program?
Corporate and in-house counsel; chief security officers; executive corporate officers; practitioners who provide advice to corporations and businesses; any practitioners involved in privacy and data security law.



Ms. Sharon Klein is a partner in the Corporate and Securities Practice Group of Pepper Hamilton LLP.  Ms. Klein is the partner in charge of the firm’s Orange County office and chair of the Privacy, Security, and Data Protection practice.  She handles a variety of corporate and intellectual property matters, in particular, helping technology and outsourcing clients grow and succeed.  Ms. Klein advises businesses on planning, drafting, and implementing privacy, security and data protection policies and “best practices,” compliance with applicable laws, regulations and rules, and crisis management and litigation strategies for non-compliance.  She is certified as an information privacy professional by the International Association of Privacy Professionals.  Ms. Klein is a frequent writer and presenter on privacy, security, and data protection matters.

Ms. Klein is admitted to practice in California and Pennsylvania. She earned her J.D. from the Temple University School of Law and her B.A., summa cum laude, from Syracuse University.


Ms. Jan Levine is a litigation partner with Pepper Hamilton LLP and is co-chair of the Commercial Litigation Practice Group.  Ms. Levine focuses her practice on health care litigation, data breach, antitrust/unfair trade practices, and directors’ and officers’ liability.  Before joining the firm in July 2007, Ms. Levine was a litigation partner with Dechert LLP and chair of that firm’s Health Law Practice Group.  Ms. Levine has completed the American Health Lawyers Association’s arbitration and advanced mediation training and the International Institute for Conflict Prevention & Resolution’s mediation training, and she is a graduate of Temple University’s Academy of Advocacy.

Ms. Levine is admitted to practice in Pennsylvania.  She earned her J.D., cum laude, from the Temple University School of Law and her B.A., summa cum laude, from the University of Pennsylvania.


Mr. Angelo Stio is a partner in the Litigation and Dispute Resolution Department of Pepper Hamilton LLP.  Mr. Stio is an experienced trial attorney who handles complex commercial disputes, class actions and derivative suits, corporate governance disputes, and college and university litigations.  Mr. Stio has litigated various issues including data breach class actions, shareholder class actions and derivative suits, UCC Article 2 disputes, breach of fiduciary duty and corporate waste claims, fraudulent transfer and avoidance actions, false claims act matters and breach of representation and warranty claims, and Telephone Consumer Protection Act (TCPA) claims.  He also has helped clients comply with both federal and state laws related to data privacy and security issues.  A frequent writer and lecturer, Mr. Stio has published articles on data privacy and security, electronic discovery, class actions and corporate governance issues and has served as a speaker at numerous seminars.


Mr. Stio is admitted to practice in New Jersey, Pennsylvania, and New York.  He earned his J.D., magna cum laude, from Seton Hall University Law School, his M.P.A. from Seton Hall University, and his B.A. from Seton Hall University.