Directors Desk LLC, File No. 092-3140, Proposed Consent Agreement #00002

Submission Number:
00002
Commenter:
Chris Connolly
State:
Outside the United States
Initiative Name:
Directors Desk LLC, File No. 092-3140, Proposed Consent Agreement

In the matter of Directors Desk LLC, File No. 092-3140, the Proposed Consent Agreement only deals with the matter of the false claim of Safe Harbor membership. I urge the FTC to also consider the substantive issue of whether or not Directors Desk complies with the basic requirements of the Safe Harbor Framework. There is a risk that consumers may believe the organisation is compliant with the Safe Harbor simply because it has now renewed its membership and the FTC has not taken any other action. However, the Directors Desk privacy policy does not include information on enforcement or complaints, and is clearly not compliant with these basic Safe Harbor requirements. In particular the privacy policy does not inform consumers that disputes will be dealt with by AAA - one of the most expensive complaints mechanisms for consumers. This information is only contained in their DOC Safe Harbor listing. Also, Directors Desk has stated that it will not cooperate with EU Data Protection Authorities, but this information is only disclosed in the DOC listing - not in their privacy policy. There is a great danger in the FTC appearing to ignore these deficiencies in the consent agreement. While the removal of the false claim regarding current membership is a good outcome for consumers, the FTC should also consider whether basic compliance with the Safe Harbor should be a pre-requisite for companies claiming that they are compliant.