Public Comments

WPF Files Comments on Federal Proposal for Human Subject Research (Common Rule)

The Nuremberg Code, an extraordinary document around ethics and research on human subjects written after the research abuses that took place during World War II, is akin to a global Emancipation Proclamation for human research subjects. The Nuremberg Code's 10 principles remain a timeless rendering of thought on what should be in place prior to any entity conducting research on human subjects, and this code forms the philosophical foundation of a regulation in the US known as the Common Rule. We have written extensive comments on the US proposal that will update the Common Rule...

WPF files comments on federal information handling to the Office of Management and Budget

The World Privacy Forum filed comments today on the Office of Management and Budget's proposed revision to a document that advises Federal agencies on how to handle the information they store. The document, OMB Circular A-130, Managing Information as a Strategic Resource , establishes policies for the management of federal ...

WPF files comments on wellness programs and privacy: urges EEOC to address privacy challenges

The World Privacy Forum filed comments with the Equal Employment Opportunity Commission about wellness programs and related privacy impacts to individuals. Many Americans now take part in employer wellness programs, and they are increasingly and justifiably concerned about the sensitive information these programs are gathering, sometimes in return for incentives such as discounts on pricing for health insurance. These comments to the EEOC address some of the most significant challenges individuals face, including voluntariness, fairness, due process, and information sharing outside of HIPAA.

Financial Privacy | Public Comments: WPF urges caution in creating new unique mortgage identifier number

WPF submits comments to CFPB about the Universal Mortgage Identifier number and Home Mortgage Disclosure Act The World Privacy Forum has recommended privacy controls for a proposed Universal Home Mortgage Identifier number, along with other privacy protections to the Consumer Financial Protection Bureau in public comments on the Home Mortgage ...

WPF urges National Science Foundation to study Statistical Parity

The World Privacy Forum submitted public comments today to the National Science Foundation in response to its request for information about a national privacy research strategy. WPF urged a research focus on statistical parity and its implementation. Statistical parity is a term WPF's Pam Dixon coined at the FTC’s Big Data, Tool For Inclusion or Exclusion? workshop in September 2014. Here is Dixon's definition of the term:

Public Comments: WPF files comments on proposed national identity standard, recommends changes

The World Privacy Forum filed technical comments on the IDPV National Standard Project today, offering key privacy recommendations on the proposed standard, Requirements and Implementation Guidelines for Assertion, Resolution, Evidence, and Verification of Personal Identity, version 5.3.1. WPF analyzed the proposed standard carefully, and sees the need for several changes to the standard to improve consumer privacy. In our comments, the intent is to help create a standard that increases security, trustworthiness of identities, and identity credentials while protecting individual privacy.

WPF Comments about Privacy and Big Data: Ethical Framework and Rights Essential

The World Privacy Forum filed comments with the U.S. Department of Commerce in response to its Request for Comments about big data, privacy, and the Consumer Privacy Bill of Rights. The White House Big Data report recognized that Big Data “raises considerable questions about how our framework for privacy protection applies in a big data ecosystem” and has the potential to “eclipse longstanding civil rights protections in how personal information is used in housing, credit, employment, health, education, and the marketplace.” This is among our concerns as well, and our comments focused on understanding big data's benefits while drawing attention to where there are significant privacy risks that need to be addressed.

WPF urges Big Data approach that addresses vulnerable populations

The World Privacy Forum's recent public comments to the White House regarding Big Data focus on using a foundation of Fair Information Principles to address issues connected to bias, error, and privacy regarding big data as applied to vulnerable populations. The comments also discuss large medical research data sets, and ...

Public Comments: WPF files comments urging the SEC to protect asset-level data privacy of consumers

The World Privacy Forum submitted comments to the Securities and Exchange Commission today requesting that the SEC do more to protect the privacy of consumers' asset information. Asset information -- the financial information attached to mortgages, car loans, and other consumer borrowing activities-- is very attractive to the consumer data industry. We would be happier with the current SEC proposal if it were practical to keep all sensitive asset-level data under the direct control of the Commission or, perhaps, the Consumer Finance Protection Bureau. Direct involvement by a federal agency, while no guarantee of a better outcome for data subjects, would provide better and clearer accountability for maintenance of the data as well as the possibility of meaningful enforcement.

Public Comments: November 2013 - WPF Comments on draft Genomic Data Sharing Policy (NIH)

WPF Comments on Genomic Data Sharing Policy for sharing, for research purposes, of large-scale human and nonhuman genomic data (NIH) Background: The National Institutes of Health published a draft Data Sharing Policy for human and non-human genomic data. The sharing is for research purposes. The World Privacy Forum comments focus ...

WPF: FAA must clarify and enhance drone privacy practices

Commercial drone privacy -- In comments filed with the FAA, the World Privacy Forum urged the agency to establish a robust privacy committee to focus on drone privacy and to clarify the applicability of the Privacy Act of 1974 to UAS test site operators. WPF also requested the FAA conduct mandatory Privacy Impact Assessments and provide a FIPS-compliant privacy notice. "We have offered our comments to the FAA with the acknowledgement that everyone has much to learn in the area of commercial drone privacy. Our suggestions to the FAA seek to increase general knowledge about drones and their effect on privacy," said Pam Dixon.

Public Comments: April 2013 - FAA must clarify and enhance drone privacy practices

Commercial drone privacy – In comments filed with the FAA, the World Privacy Forum urged the agency to establish a robust privacy committee to focus on drone privacy and to clarify the applicability of the Privacy Act of 1974 to UAS test site operators. WPF also requested the FAA conduct mandatory Privacy Impact Assessments and provide a FIPS-compliant privacy notice. ”We have offered our comments to the FAA with the acknowledgement that everyone has much to learn in the area of commercial drone privacy. Our suggestions to the FAA seek to increase general knowledge about drones and their effect on privacy,” said Pam Dixon.

Letter to FTC re: Equifax sales of consumer info to predatory lenders

In 2012, the US Federal Trade Commission brought a remarkable case against Equifax for selling consumer financial information -- which included credit scores and late mortgage payment information-- to companies offering services to consumers in financial distress. The World Privacy Forum commented to the FTC on this case, which was important for a number of reasons.

World Privacy Forum: California, Don’t Weaken Californian’s Health Privacy Laws

July 21, 2012 San Diego, California -- Today the World Privacy Forum filed comments on California's plan to harmonize existing California state law to federal health privacy laws. California's health privacy law, the CMIA, offers Californian's stronger privacy protections than national level health privacy laws. WPF urges California to reconsider its plan to weaken Californian's privacy. Executive director Pam Dixon said "The harmonization plan coming out of California's Department of Health and Human Services is not in harmony with California patients and their health privacy."

Public Comments: May 2012 - WPF Asks Presidential Commission to Protect Genetic Privacy

WPF filed comments with the Presidential Commission for the Study of Bioethics today urging the Commission to recognize the need for enhanced genetic privacy protections in a digital world. WPF noted that "The increasing identifiability of genetic data presents major privacy issues for research activities that must be acknowledged and addressed." WPF suggested four key ways that Certificate of Confidentiality programs could be enhanced for privacy protection, and urged the Commission to speak out about the importance of protecting patient privacy in research activities involving genetic information. "The Commission should advocate providing patients with reasonable controls over research uses of their data as electronic records develop and spread throughout the health care system." Public comments may be submitted to the Commission until May 25, 2012.

WPF Asks Presidential Commission to Protect Genetic Privacy

Genetic Privacy | Bioethics -- WPF filed comments with the Presidential Commission for the Study of Bioethics today urging the Commission to recognize the need for enhanced genetic privacy protections in a digital world. WPF noted that "The increasing identifiability of genetic data presents major privacy issues for research activities that must be acknowledged and addressed." WPF suggested four key ways that Certificate of Confidentiality programs could be enhanced for privacy protection, and urged the Commission to speak out about the importance of protecting patient privacy in research activities involving genetic information. "The Commission should advocate providing patients with reasonable controls over research uses of their data as electronic records develop and spread throughout the health care system." Public comments may be submitted to the Commission until May 25, 2012.

Public Comments: April 2012 - WPF asks that the full Consumer Privacy Bill of Rights be applied to MS Process

WPF filed two sets of comments with the US Department of Commerce regarding the MultiStakeholder Process and the privacy topics to be taken up. The first set of comments were WPF's formal filing of the joint Civil Society MultiStakeholder Principles on behalf of WPF and the American Civil Liberties Union, Center for Digital Democracy, Consumer Action, Consumer Federation of America, Consumers' Union, Consumer Watchdog, Electronic Frontier Foundation, National Consumers' League, Privacy Rights Clearinghouse, and US PIRG. The second set of comments were WPF's own comments to the Department. WPF urged the Department to employ a fair process, choose focused topics, and to apply the full range of the Consumer Privacy Bill of Rights to each topic.

Principles for Multi-Stakeholder Process (NTIA)

On Feb. 23, 2012, nine signatory organizations published a MultiStakeholder Principles designed to guide the NTIA MultiStakeholder Process, a self-regulatory process to develop voluntary codes of conduct with industry and civil society. The document states: "The US Department of Commerce is proposing a multi-stakeholder process for developing better applications of privacy principles. For the multi-stakeholder process to succeed, it must be representative of all stakeholders and must operate under procedures that are fair, transparent, and credible. We believe the following baseline principles will provide the multi-stakeholder process the legitimacy it needs to succeed."

Public Comments: February 2012 - WPF asks that the full Consumer Privacy Bill of Rights be applied to MS Process (Principles for Multi-Stakeholder Process)

WPF filed two sets of comments with the US Department of Commerce regarding the MultiStakeholder Process and the privacy topics to be taken up. The first set of comments were WPF’s formal filing of the joint Civil Society MultiStakeholder Principles on behalf of WPF and the American Civil Liberties Union, Center for Digital Democracy, Consumer Action, Consumer Federation of America, Consumers’ Union, Consumer Watchdog, Electronic Frontier Foundation, National Consumers’ League, Privacy Rights Clearinghouse, and US PIRG. The second set of comments were WPF’s own comments to the Department. WPF urged the Department to employ a fair process, choose focused topics, and to apply the full range of the Consumer Privacy Bill of Rights to each topic.

Public Comments: January 2012 - Regarding Face Facts: A Forum on Facial Recognition

The World Privacy Forum appreciates the opportunity to comment on the issue of facial recognition pursuant to the FTC Face Facts Workshop held on December 8, 2011. [1] The World Privacy Forum spoke on Panel 4 of the workshop, and those comments are already on the record. In these written comments, we would like to submit several key documents for the record and reaffirm several ideas from the workshop. The documents we are including as part of these comments include the World Privacy Forum’s groundbreaking report on digital signage, The One Way Mirror Society. Also included as part of these comments are the consensus privacy principles for digital signage installations that were signed by the leading US consumer and privacy groups.

Public Comments: January 2012 - Regarding Disclosure of Certain Credit Card Complaint Data

The World Privacy Forum appreciates the opportunity to submit comments to the Consumer Financial Protection Bureau’s (CFPB) proposed policy statement about the CFPB's proactive disclosure of credit card complaint data. The proposed statement appeared in the Federal Register on December 8, 2011 at 76 Federal Register 76628, http://www.gpo.gov/fdsys/pkg/FR- 2011-12-08/pdf/2011-31153.pdf and at https://www.federalregister.gov/articles/2011/12/08/2011-31153/disclosure-of-certain-credit- card-complaint-data.

WPF urges more consumer protection and redress in the Facebook FTC settlement

Facebook -- In response to the FTC's proposed settlement with Facebook over the company's multiple privacy violations, the World Privacy Forum has asked the FTC to make key changes. "We applaud the FTC for its work on the Facebook case," said executive director Pam Dixon. "We support many parts of the settlement. However, we urge the FTC to provide full redress for affected consumers by rolling back the privacy controls to the 2009 defaults, and we also urge the FTC to follow the 2004 Gateway Learning, Corp. precedent and require Facebook to disgorge profits they made from violating their privacy policy retroactively." The comment period is open to the public until December 30.