Public Comments

The World Privacy Forum has filed comments to the U.S. Office of Management and Budget in response to its Request for Feedback on Draft Guidance: Broadening Public Participation and Community Engagement with the Federal Government. WPF made three specific suggestions to OMB regarding how Privacy Act notices might be managed in a way that facilitates better feedback from those interested specifically in Privacy Act of 1974 notices, which have meaningful bearing on matters relating to data governance, privacy, and data protection.

The World Privacy Forum has filed detailed comments to the U.S. Office of Management and Budget (OMB) in response to its Request for Information on Privacy Impact Assessments. Specifically, OMB requested information about how the U.S. Federal government should update or adjust its requirements for Privacy Impact Assessments (PIAs) in regards to changes to data ecosystems brought about by Artificial Intelligence (AI). WPF provided substantive recommendations regarding administrative provisions of the Privacy Act, scalable automated AI governance tools for privacy and trustworthy AI, ensuring nimble processes for privacy and AI assessments, and ensuring balanced, skillful socio-legal-technical decisionmaking.

In December 2023, WPF submitted detailed comments to the U.S. Office of Management and Budget regarding its Request for Comments on Advancing Governance, Innovation, and Risk Management for Agency Use of Artificial Intelligence Memorandum.  OMB published the request in the Federal Register on November 3, 2023. This particular Memorandum is of historic importance, as it articulates the establishment of new agency requirements in the areas of AI governance, innovation, and risk management, and would direct agencies to adopt specific minimum risk management practices for uses of AI that impact the rights and safety of the public.

The World Privacy Forum provided comments to the FTC regarding its proposed substantive amendments to the Telemarketing Sales Rule (part 310), 87 FR 33677. Generally, WPF supports nearly all of the proposed changes in the Notice of Proposed Rulemaking. However, we are concerned about three specific areas: The expansion of consumer records kept by telemarketers

The FTC held an historic open FTC Commission meeting, during which the Chair and Commissioners conducted their business openly and also provided an opportunity for public comments. The World Privacy Forum was selected to provide a public comment, which focused on the need to update the Health Breach Notification Rule.