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The World Privacy Forum filed comments on the proposed regulations on the Genetic Information NonDiscrimination Act, or GINA. The comments request that the Equal Opportunity Employment Commission close down several potential loophole in consumer protection in the regulations. The Forum specifically asked the EEOC to consider curtailing the amount of commercially available information employers could access about employees, for example, through marketing databases. WPF also requested that those covered under GINA be required to maintain audit trails in certain circumstances, and urged that wellness programs be structured in such a way as to prevent information leakage through billing and other activities.

Tips for consumers:
Read the Terms of Service before placing any information in the cloud. If you don’t understand the Terms of Service, consider using a different cloud provider.
Don’t put anything in the cloud you would not want the government or a private litigant to see.

Cloud computing has significant implications for the privacy of personal information as well as for the confidentiality of business and governmental information. A principal goal of this analysis is to identify privacy and confidentiality issues that may be of interest or concern to cloud computing participants. While the storage of user data on remote servers is not new, current emphasis on and expansion of cloud computing warrants a more careful look at its actual and potential privacy and confidentiality consequences.

The United States has several privacy laws applicable to particular types of records or businesses. Some of these laws establish privacy standards that have bearing on a decision by a business to use a cloud provider. Others laws do not. Some laws specifically allow a business to share personal information with another company that provides support services to the business. Specific statutory references to the use of a service provider have no apparent pattern in privacy laws. Some privacy laws have them; some do not.

Report Author:
Robert Gellman, Privacy and Information Policy Consultant, .

Contributor:
Pam Dixon, Executive director, World Privacy Forum, read and commented on the report drafts and also edited the document.