A Slippery, Drizly Slope. What Security Leaders Absolutely Must Know About the FTC's Proposed 10-Year Consent Decree on the CEO of Drizly

Moderator: Michael Owens, BISO, Equifax

Featured Speaker: Aravind Swaminathan, Partner, Orrick, Herrington and Sutcliffe

He has directed more than 200 cybersecurity incident and data breach investigations, including enterprise-wide network intrusions to cyberattacks with national security implications. With extensive trial, litigation and appellate experience, he defends his clients in cyber, privacy, and payments-related class actions and other civil litigation (particularly Computer Fraud and Abuse Act matters), and when these issues lead to regulatory investigations by the Securities and Exchange Commission (SEC), the Department of Justice (DOJ), the Federal Trade Commission (FTC), and State Attorneys General. 

Starting with the Department of Justice in 2015 with the Sally Yates’ “Individual Accountability for Corporate Wrongdoing, regulators have been seeking to hold individuals (not just companies) liable because they believe that deterrence is only achievable when there are consequences for the individuals. The recent FTC consent decree against Drizzly and its CEO is just the most recent step in that direction. And it is not an outlier.

The FTCs proposed order against Drizly’s CEO will follow him for the next 10-years to make sure he implements a CyberSec program if any subsequent organization he is a senior officer at acquires data for more than 25,000 individuals. It tells a story of a company that could be told of many other organizations, and thus has critical consequences for all members of the C-Suite, from CIOs to CTOs to CISOs.

We will explore:

• What the FTC’s consent decree means for the individual going forward
• What it says about the direction that regulators are headed
• What can C-Suite members do today to avoid a similar situation

CyberEdBoard Members can RSVP for this session in the platform here: https://members.cyberedboard.io/networks/events/33687