Updating best practices for data submissions

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The FTC’s Bureau of Economics is updating its guidance regarding the best practices for submitting data and economic analysis related to antitrust investigations. BE routinely engages in econometric analysis of data obtained from the parties, third parties, and independent data vendors. Similarly, consultants retained by the parties often submit their own quantitative analyses. The importance of empirical analyses to policy decisions means that there are large returns to submitting data and analyses in ways that facilitate understanding.

The updated guidance first lays out a series of recommendations for how outside parties interact with BE and Bureau of Competition staff in order to keep their burdens low while also ensuring that FTC staff have the data necessary to evaluate a given matter. For example, the guidance provides instructions for submitting data, including specific instructions for submitting Sensitive Personally Identifiable Information (Sensitive PII) or Sensitive Health Information (SHI). Separately, the guidance lays out what outside parties can expect from BE staff during the course of an investigation. Finally, the document provides a series of recommendations about how presentations of analytical work may be structured to maximize their potential usefulness.

If you have questions related to a data submission, contact us at DataSubmissionBestPractices-DL@ftc.gov.

Comments

I am concerned about the Children's Online Privacy Protection Act (COPPA) in its current form. As of now, COPPA is extremely unclear when it comes to defining what is and is not for children. While the guidelines seem simple at first, they're so broad in scale that they could encompass many YouTube creators work that I care about, who do not make children specific content. Please revise COPPA so that the guidelines are clear about what is and isn't children's content with far less grey area. As of now, many creators are scared because they make animation, anime, video game, and toy content that is meant for adults, or at the very least, a mixed audience, but is certainly not directed towards kids, yet under the current law, they could easily be deemed as "for kids" content, making them liable to a life altering fine per video.

Speaking on behalf of YouTube creators, it makes no sense for them to be fined for YouTube's negligence. Content Creators do not data mine from their videos and never have. YouTube data mines from their videos and uses cookies to gain information on their viewers. This is information Creators never see or use. Why are creators being held responsible for draconian and career ending sized fines that are meant for corporations? Please revise COPPAs wording, and place the responsibility of Children's Protection on those who actually are violating the law, not on the Creators who make their living on the platform.

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