Online Trust Alliance (OTA)
A Preliminary FTC Staff Report on "Protecting Consumer Privacy in an Era of Rapid Change: A Proposed Framework for Businesses and Policymakers"
Donald S. Clark, Secretary Federal Trade Commission Office of the Secretary Room H-113 (Annex W) 600 Pennsylvania Ave., N.W. Washington, D.C. 20580 RE: FTC Staff Preliminary Report on Protecting Consumer Privacy - File No. P095416 Dear Mr. Clark, Thank you for providing the Online Trust Alliance (OTA) the opportunity to submit comments to the draft report. As a member-based entity with over 80 organizations representing the internet ecosystem, OTA s mission is to develop and advocate best practices to mitigate privacy, identity, and security threats to online services, brands, organizations and consumers. Through our combined efforts our goal is to enhance online trust and confidence, business innovation and ultimately the vitality of online commerce. OTA commends the Federal Trade Commission on this preliminary report. We believe this report will make an important contribution to advance best practices, protect consumers, spur innovation and enhance online trust. Efforts to support the evolving role and importance of privacy protections and self-regulatory efforts are the foundation for commerce enhancing the vitality of the internet. Business accountability, data stewardship and data protection are equally important privacy issues. Any proposed privacy framework needs to address practical protection for consumer data from abuse, exploit, breach and loss without compromising business security and fraud detection capabilities. Concurrently, OTA believes any changes to the regulatory landscape will also need to address the potential negative and disruptive impact to ad-supported content services, innovation, and commerce. The OTA looks forward to continued collaboration with browser vendors, trade organizations, government agencies and advocacy groups in advancing the goal of consumer trust and online confidence. On behalf of the Board and membership of OTA we look forward to continued dialog on these issues. Sincerely, Craig Spiezle Executive Director & President Online Trust Alliance https://otalliance.org