A Preliminary FTC Staff Report on "Protecting Consumer Privacy in an Era of Rapid Change: A Proposed Framework for Businesses and Policymakers" #00264

Submission Number:
00264
Commenter:
Bryan Melmed
Organization:
springbok media
State:
Connecticut
Initiative Name:
A Preliminary FTC Staff Report on "Protecting Consumer Privacy in an Era of Rapid Change: A Proposed Framework for Businesses and Policymakers"

There seem to be three basic arguments against ensuring consumer privacy. The weakest is that consumers appreciate targeted advertising. If it were true, I doubt the benefit would justify the cost, and if I am wrong, consumers still have the option to enable personalization. A second is that privacy laws will impose economic ruin. This is a speculative argument invoked by industry at every turn. Media has thrived without behavioral tracking, there is no reason to believe it is suddenly essential. More importantly, without a privacy framework we create incentives for further intrusion. Networks compete on how clearly they can observe user behavior, the only limitation being how sophisticated tracking technology has become. This limitation is fast evaporating. The third argument is that privacy laws are unnecessary because the risk is manageable. And yet, just this year, thousands of people will struggle to recover from identity theft. Data is vulnerable even in the most responsible hands. No matter what is promised by way of self-regulation, having your personal details encoded, digitized, and shared across multiple parties is inherently dangerous. We are racing to disaster with the certainty of the Titanic. It is time to change course.