FTC to Examine Effects of Big Data on Low Income and Underserved Consumers at September Workshop #00066

Submission Number:
00066
Commenter:
Carl Szabo
Organization:
NetChoice
State:
District of Columbia
Initiative Name:
FTC to Examine Effects of Big Data on Low Income and Underserved Consumers at September Workshop
Matter Number:

P145406

Attached are the comments of NetChoice. In general we ask the FTC to engage in research and analysis of actual harms, harm-benefit analysis, and an existing law analysis of big data uses. We recommend this analysis follow the following 3-step approach: 1. Search for actual harms: Look to see if consumer complaints point to real-world (not theoretical) harms which exist from the use and growth of big data. Such analysis should separate out actual harms from general privacy anxiety. 2. Balance harms: If harms exist, they must be balanced against the actual benefits of big data (some of which are discussed within these comments). This balancing should include down-stream impact of limitations on the use or collection of big data. 3. Analyze existing laws. To avoid overly restrictive new laws, the FTC should research existing laws that mitigate identified harms not offset by benefits. Our comments are further outlined in the attached.