The Data Broker Toolkit: How Enforcers Can Protect Privacy and Stop Data Broker Abuses
We’re releasing the Data Broker Toolkit: a resource for understanding and addressing data broker practices through an enforcement lens. This document outlines key data broker resources for enforcers.
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This document is organized into four sections for clarity and usability:
- Section 1: Data Brokers Overview. This section provides a basic overview of contextual resources on data brokers to help enforcers get up to speed on the technical landscape.
- Section 2: Case Overview. This section provides a quick reference list of notable data broker cases and relevant cases – with links to the complaint, order, and press release.
- Section 3: Remedies Overview. This section outlines common remedies in data broker cases.
- Section 4: Sources For Case Data. This section outlines various ways to get information about potential cases.
- Section 5: Complaint & Order Table. This section consolidates case information into a quick reference table that outlines core allegations and the remedies imposed. It begins with the facts of the conduct, then identifies applicable legal theories, potential remedies, and real-world case examples.
The goal is simple: make it easier for enforcers, investigative journalists, practitioners and policymakers to understand how the law applies to data brokers, and where the gaps remain.
You can access the toolkit here.
Why now? Data brokers play an outsized role in today’s information economy. These companies – many who you probably have never heard of – quietly collect, package, and sell personal information—often without people realizing it’s happening. Their practices raise serious concerns and can lead to harm to millions of consumers. Our toolkit compiles key cases, enforcement actions, and resources to make these issues more accessible and to enable those with the authorities to take action.
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Contributors in alphabetical order by last name:
Erie Meyer is a Senior Fellow at Georgetown Institute for Technology Law & Policy, Former CFPB Chief Technologist
Stephanie T. Nguyen is a Senior Fellow at Georgetown Institute for Technology Law & Policy, Former Chief Technologist at the Federal Trade Commission
Samuel A.A. Levine is a Senior Fellow at UC Berkeley Center for Consumer Law & Economic Justice, Former Bureau of Consumer Protection Director at the Federal Trade Commission