Proposed Consent Agreement In the Matter of Facebook, Inc., FTC File No. 0923184 #00060 

Submission Number:
00060 
Commenter:
Michael Schiffer
State:
Illinois
Initiative Name:
Proposed Consent Agreement In the Matter of Facebook, Inc., FTC File No. 0923184

This agreement fails to go far enough, particularly given Facebook's persistent "easier to get forgiveness than permission" history. At a bare minimum, users need to be able to maintain knowledge of and control over the information they provide to Facebook, including a right of deletion (with deletion to be confirmable, and any failure to comply subject to civil and criminal penalities, a right to know what information has been provided about them and to whom. Likewise, any privacy policy changes should be required to have a prominent announcement at least thirty days before implementation. Most importantly, Facebook should be subject to random, unannounced audits by third parties, rather than having them be on a specific predetermined schedule. These audits should limited in number to not be unduly burdensome, but Facebook should not be in a position where it can arrange to only appear to be in compliance when a known deadline is approaching.