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Public Comments: December 2006 – Confidential Information Protection and Efficiency Act of 2002 (CIPSEA)

The World Privacy Forum submitted comments to the Office of Management and Budget regarding proposed guidance on Title V of the e-Government Act. The proposed guidance did not address the relationship between CIPSEA and the USA PATRIOT Act Section 215, and guidance regarding identifiability and the Privacy Act of 1974 needs to be further refined. WPF suggests that OMB consider developing a formal statistical confidentiality seal controlled by a federal agency. The purpose would be to provide an identifiable marker that would tell individuals if the information they provide will receive the highest degree of confidentiality protection available under law.

Public Comments: March 2006 – IRS on Tax Information Sharing

The proposed changes to the regulations represent an important effort to increase taxpayers’ awareness of what is done with their personal information. However, the updated regulations fail to adequately safeguard taxpayer privacy because they neglect to protect information once it is disclosed, allow consent that is less than voluntary, and carry penalties that are not harsh enough to ensure tax return preparers obey the law.

Public Comments: January 2006 – Identity theft survey

The World Privacy Forum submitted comments in response to the Federal Trade Commission’s request for feedback on its upcoming identity theft survey. The FTC identity theft survey is one of the most quoted surveys on the subject. The World Privacy Forum requested changes and clarifications to the survey, including adding questions about security breach notices and clarifying existing questions about medical identity theft, among other issues.