Privacy Ethics

WPF files comments on deeply flawed SEC plan

Financial privacy and SEC — The World Privacy Forum filed comments today criticizing the SEC proposed regulations that would release an unprecedented amount of financial details about individual borrowers through the EDGAR database. The WPF was joined by other privacy, consumer, and human rights organizations in its comments, which focused on the privacy issues with the proposed regulations. Pam Dixon, executive director of the WPF, stated in the comments that the SEC’s new regulations would “Place on the public record and online the largest amount of personal financial information about borrowers ever disclosed, including information never before made public.” The comments also note that the SEC’s plan greatly increases the risk of identity theft for individual borrowers whose information will be released publicly.

World Privacy Forum comments on genetic non-discrimination to HHS

Genetic non-discrimination regulations (GINA) — The World Privacy Forum filed comments on proposed regulations for implementing Title I of GINA, the Genetic Non-Discrimination Act. The WPF requested a change to the proposed regulations, asking the Department of Health and Human Services require immediate posting of revised notices of privacy practices on the web sites of affected health plans. Under the proposed regulations, written notice of revised privacy practices to individuals could be delayed due to the cost of postal mailing. The WPF noted that a revised privacy notice posted on a health plan’s web site would not incur postal costs, and that regulated entities should take this minimum step to inform consumers of any changes regarding privacy practices affecting genetic non-discrimination.

Testimony: The Modern Permanent Record and Consumer Impacts from the Offline and Online Collection of Consumer Information

I am particularly interested in developments related to online and offline data flows of consumer information. Given the advances in technology that have significantly broadened and deepened the scope of consumer data collection practices, and given the new ways that these technologies and practices can shape and impact an individual’s experiences and opportunities, I believe the decisions that this Committee arrives at will be of lasting importance. Given the transition our society is undergoing from analog to digital, it is crucial to question what changes the new environment brings, what new controls it includes, and its meaning for our day-to-day lives. It is especially crucial to carefully examine and to discuss the effects these developments will have for the consumer. We must look for a fair balance between benefit, risk, and harm.

WPF is signatory to the Madrid Declaration; global privacy standards for a global world

Madrid Declaration — A significant civil society document with more than 100 signatories worldwide has been published in conjunction with the 31st annual meeting of the International Conference of Privacy and Data Protection Commissioners. The document, known as the Madrid Declaration, affirms support for the complete canon of fair information practices as expressed by the OECD, affirms support of privacy as a fundamental human right, and warns that “the failure to safeguard privacy jeopardizes associated freedoms, including freedom of expression, freedom of assembly, freedom of access to information, non-discrimination, and ultimately the stability of constitutional democracies.”