USACM Comments on Federal Trade Commission Online Privacy Report

On February 18th, USACM submitted comments in response to the Federal Trade Commission’s (FTC) preliminary staff report concerning online privacy. Titled “Protecting Consumer Privacy in an Era of Rapid Change,” the report outlines a proposed privacy framework involving the following general principles:

  • Companies should integrate privacy into their regular business operations (a Privacy by Design approach)
  • Consumer choice needs to be presented in a more streamlined fashion than current practice
  • Companies should increase the transparency all of their data practices, including those in the parts of their business that don?t engage with consumers directly.
  • The FTC also sought comment on the development and use of a Do Not Track policy comparable to the Do Not Call list to reduce telemarketing calls.

    As the focus of the report shares significant overlap with the online privacy report from the Internet Policy Task Force at the Department of Commerce, there is also a fair amount of overlap between USACM’s comments to the FTC and its comments to the Department of Commerce. USACM comments to the FTC discuss the need for a dataflow-based lexicon and enhanced privacy risk models, as did our comments to the Department of Commerce.

    These comments did spend some time outlining how to approach a possible Do Not Track system. Recognizing that a Do Not Track option is an effort to move beyond standard opt-in and opt-out choices, USACM encouraged the FTC to define Do Not Track in a way that was technology neutral. It is also important to have a Do Not Track system that allows for a variety of consumer choices. There must be some options between track everything and track nothing so that consumers can really craft a personalized Internet experience that reflects their preferences.

    The comments submitted are just a part of the entire process the FTC is going through to develop new guidance for improving consumer privacy online. A final report, or even proposed regulations, are several months away.

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