Facebook faces government investigations on both sides of the Atlantic after recent revelations that Cambridge Analytica, a British political data firm with ties to President Trump’s 2016 campaign, collected and used the personal information of more than 50 million Facebook users in a manner that violates Facebook’s stated policy regarding access, disclosure, and use of personal information. Legislators in the U.S. and the UK have called for hearings.

The Federal Trade Commission (“FTC”) has confirmed it is conducting an investigation into whether Facebook violated the terms of its November 2011 consent decree requiring it to, among other things, “not misrepresent . . . the extent to which it maintains the privacy or security of [personal] information,” and “establish and implement, and thereafter maintain, a comprehensive privacy program that is reasonably designed to (1) address privacy risks related to the development and management of new and existing products and services for consumers, and (2) protect the privacy and confidentiality of [personal] information.” Several state attorneys general have also announced investigations, and Facebook faces at least one a shareholder lawsuit alleging that Facebook did not properly disclose the third-party access to users’ personal information.
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