|Received:||10/8/2009 5:16:41 AM|
|Agency:||Federal Trade Commission|
|Rule:||World Innovators, Inc.; File No. 092-3137; Proposed Consent Agreement|
Comments:Clearly, this consent order applies only to the very specific simple facts in the complaint, that World Innovators improperly claimed compliance with the principles of Safe Harbor. Sadly, the consent order provides no real penalty against World Innovators for this misleading of the public; provides no information to the public as to whether World Innovators actually did reasonably protect the information security and privacy of the public; and provides no incentive for World Innovators to actually come in to compliance with the principles of Safe Harbor. Instead, World Innovators may simply remove all claims regarding privacy compliance, and be consider compliant with this order. To these ends I encourage the Commission to further investigate World Innovators, specifically in the areas of determining whether World Innovators actually did reasonably respect and protect consumer security and privacy, and thereafter to update the consent order if appropriate. Even if no further damage was found to have been done to the public, and/or it is beyond the scope of the Commission's power to investigate a complaint beyond the specific allegations of the complaint, I encourage the Commission to impose some meaningful penalty, in order to provide incentive to all organizations which hold or use personal information to respect consumer privacy and security.