Request for Comments and Announcement of FTC Workshop on Spring Privacy Series #00008

Submission Number:
L Mingo
Initiative Name:
Request for Comments and Announcement of FTC Workshop on Spring Privacy Series
Matter Number:


SUBJECT: REQUEST FOR COMMENTS AND ANNOUNCEMENT OF FTC WORKSHOP ON SPRING PRIVACY SERIES, PROJECT NO. P145401 DATE: 12/4/13 To Whom It May Concern: Please address the additional questions listed below in each seminar. In general, I am most concerned about multiple companies combining their consumer data. Privacy is best protected when an individual company or website asks a given consumer only for data that are relevant to that consumer's use of that company's services or products and that consumer's data are not shared with other companies except under very limited circumstances that are clearly described to the consumer upfront and are directly related to the consumer's use of the original company's services or products. Consolidated data sets create a very high risk of abuse of data and invasion of privacy. Data brokers should be monitored extremely closely for violations of privacy and anonymity and for data inaccuracies. Identity theft is too prevalent and too destructive for the FTC to not take severe measures to protect consumers' data and privacy. Thank you for the opportunity to comment on this very important series of seminars. Mobile Device Tracking 1. Are companies combining their data to create even more extensive records of individuals' movements and behaviors? Are companies linking mobile data to other kinds of data? 2. How can consumers best be informed that companies are tracking their movements and behaviors? That is, at what point should consumers learn that a given company is tracking their movements and behaviors, at what point should a consumer be able to opt out, and to what extent should consumers be given direction as to how to opt out and/or avoid being tracked? 3. Can consumers request that previously collected mobile device data be deleted, and who will provide oversight to ensure that the data are deleted? Alternative Scoring Products 1. How is alternative scoring not profiling or discrimination? 2. Where are the data brokers and companies obtaining the underlying input data and algorithms? To what extent are they testing it for accuracy? Are the data brokers and companies combining their data with data from other data brokers and companies? 3. How can companies best inform consumers about their use of this practice? 4. How can consumers opt out of this practice? Can they request that previously collected data be deleted from company records and from data broker records? 5. Who will provide oversight to ensure that consumers' privacy and rights are protected? 6. How will companies provide redress to consumers who are wronged based on inaccurate and/or incomplete data and algorithms? Is the data broker or the company who uses the data at fault? How will consumers know if they have been wronged? Consumer Generated and Controlled Health Data 1. What data are health websites collecting about visitors to their sites in general and per individual? 2. To what extent are health websites checking the data for accuracy? 3. What are health websites using the data for, and to what extent is it personally identifiable information? 4. Are the health websites combining their data with that from other companies or otherwise sharing or obtaining additional data with/from other companies? 5. How can health websites best inform consumers about their data collection practices? 6. How can consumers opt out of having their health website searches and other data monitored and recorded? Can they request that previously collected data be deleted? Sincerely, L. Mingo