Submission Number: 00047
Received: 12/20/2011 1:38:35 PM
Commenter: Kevin O'Neil
Organization: CYVA Research
Agency: Federal Trade Commission
Initiative: Proposed Consent Agreement In the Matter of Facebook, Inc., FTC File No. 0923184
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I believe the FTC settlement should be strengthen as recommended by the EPIC Advisory Board, the Privacy Coalition, and the Trans-Atlantic Consumer Dialogue.
- Restore Original Settings. Facebook should default to the privacy
settings available to users in 2009.
- Know What They Know. Facebook should let users have access to all
data that Facebook keeps about them.
- Facial Recognition. Facebook should stop making facial recognition
profiles without users' consent.
- Transparency. Facebook's privacy reports should be made publicly
- Secret Tracking. Facebook should stop secretly tracking users across
Additionally, innovative privacy and security technologies should be funded through the financial penalties paid by firms that violate our laws and citizen-consumer choice with regards to their human-digital right of informational self-determination. Funds should be directed to developing user-controlled identity products and services that empower the principles of human-digital dignity and human-digital integrity.
Fundamentally, Facebook and other firms do not respect human-digital dignity and the right of individuals to control their personal information, anytime, anywhere: informational self-determination. An individual’s access control and data processing policies should never be separated from their personal information assets: human-digital integrity. Citizen-consumers should not be separated from their assertive ability to control their personal information, wherever it exist.
Our proposed user-controlled identity solutions have languished (lack of funding) due to the avarice, powerful anti-privacy lobbyist activities and extremely lucrative data slave trade practices of Facebook and others. The violent and pernicious harvesting of personal information remains largely unchecked with lawmakers and regulators habitually in a conflicted catch up mode.
Parallels to the Transatlantic slave trade that lasted for 400 years is worthy of consideration in understanding the forces that perpetuate a very profitable and callous enterprise that denies the humanity and self-determination (liberty) of human beings. Today we have data slave traders who deny human-digital dignity, violently harvesting personal information declaring us all their property to be worked and exploited as they see fit…see attachment.
I am recommending a set of principles to guide the architecture and engineering of future information systems that collect and process personal information.
Enterprise Architecture Principle
Name: Human-Digital Integrity
Related principle: Human-Digital Dignity
Never separate a person from their ability to control, at will, their personal information wherever it exists.
Privacy matters. Informational self-determination: the right of individuals to control, at will, their personal information is essential to liberty and human dignity.
The violent, disrespectful, always on capture and monetization of personal information is out-of-control. Enterprises that promote intrusive citizen surveillance capabilities undermine any notion of consumer to business trust and fidelity. Citizens do not trust, nor should they trust data slave traders.
Trust wars are inevitable as businesses compete for consumer-spend. To what extent is privacy and control over my personal information important in our information society and digital economy? Privacy hostile products/services are a deal breaker, a huge turn-off for informed citizen-consumers; a non-issue for the apathetic crowd who feels powerless to challenge corporate greed and indifference.
Architects, engineers, consumer relations, marketing, customer support, corporate lawyers and executives should assess the impact of privacy and security architecture choices. Respecting human-digital dignity is a critical choice and will be a key basis for consumer trust.
CYVA Research Corporation