Whatever Happened to “No Harm No Foul”?

The FTC’s proposed settlement shows that the FTC is focusing its limited resources on penalizing companies for unintentional actions that do not result in any actual user harm rather than directing these resources at cases where users suffer real harm or companies intentionally tried to mislead users. As a result, this proposed settlement may discourage companies from fully disclosing details about their data handling practices in the future.