USACM Offers Recommendations On Data Privacy Codes of Conduct

By David Bruggeman
April 2, 2012

Part of the Obama Administration’s proposed online privacy initiative involves consumer data privacy codes of conduct. These codes would be developed through a multi-stakeholder process, and the National Telecommunications and Information Administration (NTIA) is responsible for convening those processes.

To that end, NTIA released a request for comment in early March (the deadline was extended to April 2), and USACM filed comments earlier today. Much like our comments on the governance of the National Strategy for Trusted Identities in Cyberspace (NSTIC), the request and our comments are focused on issues of process and focus.

In our comments we encourage the NTIA to focus not only on the technologies and applications identified in their request for comment, but also to consider the assessments of privacy risks associated with these technologies and applications. We also recommended that the process – both the meetings and the output of those meetings – be made available to the public in formats that are easily reusable. Much like with NSTIC, trust is going to be an important contributor to the success or failure of the consumer data privacy codes of conduct.