In the Matter of Md7, LLC, File No. 172 3172
It is my understanding that this Notice of Violation and Proposed Consent Agreement regards the company Md7, LLC and its failure to comply with US/EU data privacy regulations in addition to falsely representing the company's compliance with these laws. The various parts of the consent agreement which concern guaranteeing compliance with the EU-US privacy shield framework are in my opinion appropriate, however I think the FTC should go further in its consideration of punitive consequences for Md7's misrepresentation of compliance. Assuming that the wireless carriers which contracted with Md7 maintain and implement some sort of quality and CSR standards for third party agents, by falsely representing compliance with the privacy framework, Md7 may have put personal consumer information at risk unbeknownst to the carriers contracting for a good/service . This is unacceptable and should be met with stern measures to dissuade similar falsities in the future. I recommend a monetary fine and mandatory federally-certified compliance before Md7 can continue business operations with the US. Thank you for the opportunity to comment.