Submission Number: 00355
Received: 2/18/2011 12:26:12 PM
Commenter: C Calderone
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
Comments on FTC Proposed Privacy Framework
I offer the following simple proposals in response to requests for comments:
The FTC “call to increase transparency” seems counterproductive. What consumer is going to understand all the implications of allowing meta-data collection? Even putting it into plain English and saying whether data is scrubbed or tokenized is unlikely to promote real understanding and awareness. I believe more good would come from the FTC publishing minimum standards for safeguarding information.
FTC could and should set universal privacy definitions and the use of a logo or identifiable mark makes sense. What a certain “privacy” standard means needs to be consistent and understood by both retailers and consumers as they move from site to site.
Let us assume that people are generally not pro-active. The FTC acknowledges that people will not read more than a quick blurb or two about their privacy rights and have required shorter policies. To further assist with this, a defined and coded simple standard will do far more to protect consumers than elaborate “by design” models will. As an attorney, even I do not read complete privacy policies on many of the websites I visit. However, a simple blurb, or a “PG” rating and a link to a wiki definition, would be easy for anyone to understand.
Why do consumers need to have access to "their data?" In most instances, the only safe option is to have it anonymized and/or deleted.