Public Comments

WPF urges US Federal Trade Commission to re-examine data breach notification requirements for health data in Flo Health proposal

The World Privacy Forum has submitted comments to the FTC regarding its proposed consent order In the Matter of Flo Health, Inc. requesting that the FTC conduct further analysis regarding the FTC Health Data Breach Rule and its potential applicability to the alleged unconsented sharing of women’s pregnancy, menstruation, mental health, and other data with

WPF comments on European Commission proposal for new Health Authority

The European Commission has proposed the creation of a new European Health Emergency Preparedness and Response Authority, HERA. WPF provided comments regarding the proposal, urging the Commission to ensure from the outset that HERA will fulfill its mission with a focus on data interoperability and will include specific data governance and protection measures that will analyze

FTC proposes precedent-setting face recognition settlement: photo app company must delete consumers’ photos and the algorithmic models it developed using the photos

The FTC has proposed a crucially important settlement with a photo app developer, Everalbum Inc., which the FTC says “deceived consumers about its use of facial recognition technology and its retention of the photos and videos of users who deactivated their accounts.”  The proposed FTC settlement will require the company to obtain consumers’ express consent

WPF responds to HHS and urges it to keep privacy protections in HIPAA strong

WPF has written to the US Department of Health and Human Services advising them on their Request for Information (RFI) about possible changes to HIPAA privacy and security protections. The RFI has a number of suggestions that, should they become part of a formal proposal, would significantly weaken HIPAA privacy protections.