Submission Number: 00008
Received: 12/1/2010 4:29:04 PM
Commenter: Robert L. Couch
Agency: Federal Trade Commission
Initiative: A Preliminary FTC Staff Report on "Protecting Consumer Privacy in an Era of Rapid Change: A Proposed Framework for Businesses and Policymakers"
Attachments: No Attachments
The FTC should convert this preliminary report to regulation as rapidly as possible. Currently internet users have no recourse and extremely few technical resources to counter internet behavior tracking technologies, even when aware of what is taking place. Most users have no idea they are being stalked in virtual space for private gain by others. Even if an internet user tracking firm tells all users that it will not collect their individual information, how can an individual verify the corporate claim?
My rights to privacy and freedom of movement in virtual space as a law-abiding, individual citizen are being threatened by private companies for their own financial gain, using powerful behavioral tracking technologies under development and now being deployed surreptitously.
If a Government were as a matter of course to collect the kinds of tracking data (I call it financial stalking) on all citizens that internet user behavior tracking firms are now beginning to deploy, there would be a huge public outcry if not actual litigation mounted to stop such interference with private lives. Corporations should not be held less accountable than Government in this regard.
The FTC might also consider how close the legal boundary is and should be between the emerging internet user behavior tracking technologies and the statutory restraints already embodied in law regarding "wiretapping activities." Corporations may say that they will not disclose personal identity information to the consumers of their tracking technologies. But the deployed technologies will have the ability to collect that information, even if it is not intended to be conveyed to tracking technology clients. Why should a for-profit firm be held to a lesser legal standard than Government regarding data collections that occur without the knowledge of the subjects of the collects?
If individual internet users want or do not mind their internet behaviors being tracked, they can "Opt in" to the technologies on a case by case basis. The default settings in all internet user interfaces should be "OPT OUT."