Consumers, businesses and government agencies increasingly are storing data and using services “in the cloud.”  This has profound implications for consumer protection.  Consumers are entrusting family photos, documents, and personal information to others, in an environment where expectations, best practices, and even the law are unclear.  Businesses may outsource processes to the cloud without fully contemplating the implications for their customers’ privacy.  The growing use of the cloud creates new challenges for consumer protection and privacy, but it also intensifies problems that have long existed.