Proposed Consent Agreement In the Matter of Baker Tilly Virchow Krause, LLP #00002

Submission Number:
Chris Connolly
Outside the United States
Initiative Name:
Proposed Consent Agreement In the Matter of Baker Tilly Virchow Krause, LLP
Matter Number:


[For privacy reasons, please do not display my postal code. UK postal codes identify the actual house]. Dear FTC enforcement team, I welcome the action you have taken regarding the false claim of Safe Harbor membership by Baker Tilly. While I support the overall direction of the draft consent order, I believe the FTC should take action to ensure that Baker Tilly also complies with Principle 7 of the Safe Harbor. This requires organisations to correctly identify an independent dispute resolution provider, and provide consumers with contact information for that service. The Baker Tilly privacy policy states: "For complaints that cannot be resolved between Baker Tilly Virchow Krause, LLP and the complainant Baker Tilly Virchow Krause, LLP has agreed to participate in the dispute resolution procedures of United States Council for International Business pursuant to the Safe Harbor Principles. Baker Tilly Virchow Krause, LLP is domiciled in the state of Illinois. The state of Illinois will be the applicable jurisdiction for dispute resolution." The stated dispute resolution service does not exist. It has been mis-described and mis-identified. The stated jurisdiction is also false, as according to Baker Tilly's Department of Commerce self certification record, disputes will be resolved in Europe by the EU DPA Panel. It is very important that the FTC consent orders in Safe Harbor cases do not overlook compliance with the substantive provisions of the Safe Harbor. Principle 7 is an important protection for consumers.