16 CFR Part 314, Standards for Safeguarding Customer Information, Project No. P145407
I understand the intrinsic value that fair information practices to the economy and innovation. But without clear and consistent lines for entities engaging in certain practices, the balance these principles are intended cannot be achieved. The same consumer risks ISP pose to consumers are applicable for edge providers, specifically mobile operating systems and connected applications and services that enable interactions with the data subject or their data. The primary areas of development for edge providers are capabilities designed for monetization and even more prolific methods of passive and active interaction with data subjects and their data. If companies can claim tracking, profiling and other commercial data practices are "innovation" and beneficial to consumers under fair information practices, then they service to enable deception rather than innovation.I believe edge providers should be subject to the same obligations as ISPs. I have no preference whether these actions are regulated by the FTC, FCC or both. However, neither agency has adequately recognized the extent of risk edge providers pose to consumers.