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Expert Analysis

Privacy For Franchisors — Tough Rules Without Standards

Law360, New York (June 16, 2014, 3:47 PM EDT) -- Where a zealous regulator has a great deal of power, but no published standards or accountability to legislatures or courts, and appears to exercise limited discretion in applying a single, onerous penalty on all entities it regulates, your object as a regulated entity might well be to escape the notice of the regulator. At the time of this writing, that is the situation faced by franchisors whose privacy and information security practices are regulated by the Federal Trade Commission....

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