Patrick Fowler and Andrew Hardenbrook of Snell & Wilmer write:
Companies that are looking to sell, transfer or buy personally identifiable information (“PII”) via bankruptcy asset sales would be wise to confirm that such a transfer is consistent with the debtor’s privacy policy. If it is not, the Federal Trade Commission may seek to block the sale until the debtor agrees to comply with the policy, or the bankruptcy court appoints a consumer privacy ombudsman to advise the court on the privacy implications of the sale.
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