Privacy

Public policies should leverage the existing framework of the Fair Information Practice Principles. These principles provide the right balance between setting responsible standards for the collection and management of consumer information while at the same time providing room for companies to develop new and innovative online products and services that consumers want.

Public policies should grant the Federal Trade Commission discretion and flexibility to adapt, update and strengthen the application of the Fair Information Practice Principles to changing technologies and consumer needs. Specifically:

• The FTC should be directed (in partnership with the private sector) to focus on developing privacy notices that are simpler, easy to read and understand, and that provide meaningful choice.
• Public policies that focus on educating the public and consumers about their rights and the importance of reviewing privacy notices are vitally important. Consumers drive the marketplace for new products and services and they should be empowered to protect their privacy.
• Any public policy proposal should make a distinction between good actors that inadvertently do bad things versus bad actors that aim to do bad things. A safe harbor program will accomplish this task. Safe harbor programs promote responsible conduct and provide a degree of certainty to businesses that collect, store and or transmit personally identifiable information.

Policy Goal: We support legislation that enhances FIPPs and supports the ability of the FTC to enforce FIPPs. Legislation such as H.R. 2221, the Data Accountability and Trust Act, have many commendable elements.