Consumer Privacy

WPF on EASA: Self-Regulation on Online Behavioral Advertising No Longer Credible

Comments on EASA –The World Privacy Forum submitted comments today on the European Advertising Standards Alliance’s Best Practice Recommendation on Online Behavioural Advertising. Our comments focus upon three key areas: First, the EASA recommendation fails to recognize the protection of consumer privacy in Online Behavioral Advertising (OBA) as a key policy goal. Second, the recommendation’s protections are narrow, creating illusory protections for user privacy, whether or not they opt out of OBA. Finally, we critique the oversight and compliance mechanisms, which are not likely to foster consumer confidence nor police the industry. Drawing upon the WPF’s 2007 report, The NAI: Failing at Consumer Protection and at Self-Regulation, the comments argue that EASA’s approach suffers from the same weaknesses as self-regulatory approaches deployed in the United States, and that European lawmakers should not replicate the failed American approach. Law students from the Samuelson Law, Technology & Public Policy Clinic helped draft the comments as part of an ongoing project on consumer privacy and OBA.

Public Comments: February 2011 WPF Responds to FTC’s Report on Privacy

The World Privacy Forum filed comments with the FTC in response to its preliminary staff report, Protecting Consumer Privacy in an Era of Rapid Change: A Proposed Framework for Businesses and Policymakers. In our comments, we urge the FTC to take affirmative steps to protect consumer privacy online and offline. Our comments include a brief history of privacy self regulation, and point out how privacy self regulation has consistently failed. The comments also discuss Do Not Track, and urge the FTC to take a broader look at tracking protections for consumers. WPF also specifically requested that the FTC identify credit reporting bureaus subject to Fair Credit Reporting Act regulations and assist consumers in locating those bureaus.

WPF Responds to FTC’s Report on Privacy

WPF Comments on the FTC Privacy Report — The World Privacy Forum filed comments with the FTC in response to its preliminary staff report, Protecting Consumer Privacy in an Era of Rapid Change: A Proposed Framework for Businesses and Policymakers. In our comments, we urge the FTC to take affirmative steps to protect consumer privacy online and offline. Our comments include a brief history of privacy self regulation, and point out how privacy self regulation has consistently failed. The comments also discuss Do Not Track, and urge the FTC to take a broader look at tracking protections for consumers. WPF also specifically requested that the FTC identify credit reporting bureaus subject to Fair Credit Reporting Act regulations and assist consumers in locating those bureaus.

WPF comments about Personal Health Records and online advertising

Health privacy — The World Privacy Forum filed comments today about how medical records and other health information is intersecting with online advertising and online activities. The WPF comments were filed with the Department of Health and Human Services in response to its request for comments on personal health records, privacy, and social media.