Penalty Amount
$220,000
The FTC settled with Kohl's Department Stores for violating the Fair Credit Reporting Act by failing to provide identity theft victims with access to their business transaction records within 30 days. Kohl's agreed to pay a $220,000 civil penalty and must implement measures to comply with FCRA requirements, including providing records promptly and posting a notice on its website.
Kohl's must pay a $220,000 civil penalty, provide identity theft victims with access to business transaction records within 30 days upon verification, post a notice on its website informing victims how to obtain records, and certify that it has contacted past victims who were denied access.
In-house legal teams should review customer agreements, privacy policies, and fraud response procedures (including any data processing or vendor agreements involving consumer transaction data). Focus on clauses governing responses to identity theft requests, specifically the timeline for providing business records (FCRA Section 609(e) requires disclosure within 30 days) and the scope of information to be disclosed (including perpetrator details like names and contact information). Updates may be needed to ensure policies explicitly commit to timely, complete record provision; implement verification processes for request legitimacy; train staff on FCRA obligations; and include clear consumer notices about their rights to such records. Employee handbooks and incident response plans may also require revision to reflect these duties.
Entity
Kohl's Department Stores, Inc.
Also known as: Kohl's
Industry
RetailOfficial Press Release
https://www.ftc.gov/news-events/news/press-releases/2020/06/ftc-reaches-settlement-kohls-over-allegations-it-failed-provide-victims-information-related-identity
kohls complaint filed 6.10.2020 1
https://www.ftc.gov/system/files/documents/cases/kohls_complaint_filed_6.10.2020_1.pdf
kohls final order
https://www.ftc.gov/system/files/documents/cases/kohls_-_final_order.pdf
Federal Trade Commission Enforcement Page
https://www.ftc.gov/enforcement
"Kohl’s Department Stores, Inc."
"pay a civil penalty of $220,000"
"Fair Credit Reporting Act (FCRA)"
"Section 609(e) of the FCRA"
"Kohl’s refused to provide information identifying the thieves to identity theft victims"
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