Kim Phan

Career

Kim Phan is a privacy and data security attorney who counsels companies in federal and state privacy and data security statutes and regulations. Her work encompasses strategic planning and guidance for companies to incorporate privacy and data security considerations throughout product development, marketing, and implementation.

Kim also provides e-commerce and mobile counseling, including adapting an augmented reality mobile game for a retail client, conducting online behavioral advertising assessments of websites to update and enhance website privacy policies, adapting website functions for accessibility in compliance with the Americans with Disabilities Act (ADA), and establishing employee training on social media interactions with consumers.

In addition, Kim provides guidance to clients on regulatory compliance matters, including supervisory and enforcement interactions with the Consumer Financial Protection Bureau (CFPB), the Federal Trade Commission (FTC), and other federal regulatory agencies. She has successfully represented multiple national companies through the FTC investigatory process, resulting in “no-action” letters. She has also counseled a national consumer reporting agency through its CFPB compliance obligations, including conducting risk assessments of consumer products and services, updating policies and procedures, and establishing an audit process to assess compliance with federal consumer financial laws. Kim also has counseled clients through state attorneys general and departments of consumer protection investigations.