Public Comments

Apr 02 2024

WPF Comments to OMB regarding AI and Privacy Impact Assessments

The World Privacy Forum has filed detailed comments to the U.S. Office of Management and Budget (OMB) in response to its Request for Information on Privacy Impact Assessments. Specifically, OMB requested information about how the U.S. Federal government should update or adjust its requirements for Privacy Impact Assessments (PIAs) in regards to changes to data ecosystems brought about by Artificial Intelligence (AI). WPF provided substantive recommendations regarding administrative provisions of the Privacy Act, scalable automated AI governance tools for privacy and trustworthy AI, ensuring nimble processes for privacy and AI assessments, and ensuring balanced, skillful socio-legal-technical decisionmaking.

Mar 27 2024

WPF comments to OMB regarding its Draft Memorandum on establishing new Federal Agency requirements for uses of AI

In December 2023, WPF submitted detailed comments to the U.S. Office of Management and Budget regarding its Request for Comments on Advancing Governance, Innovation, and Risk Management for Agency Use of Artificial Intelligence Memorandum. OMB published the request in the Federal Register on November 3, 2023. This particular Memorandum is of historic importance, as it articulates the establishment of new agency requirements in the areas of AI governance, innovation, and risk management, and would direct agencies to adopt specific minimum risk management practices for uses of AI that impact the rights and safety of the public.

Aug 03 2022

WPF advises FTC regarding proposed changes to the Telemarketing Sales Rule

The World Privacy Forum provided comments to the FTC regarding its proposed substantive amendments to the Telemarketing Sales Rule (part 310), 87 FR 33677. Generally, WPF supports nearly all of the proposed changes in the Notice of Proposed Rulemaking. However, we are concerned about three specific areas: The expansion of consumer records kept by telemarketers

Jul 01 2021

WPF urges FTC Chair and Commissioners to update FTC Health Breach Notification Rule

The FTC held an historic open FTC Commission meeting, during which the Chair and Commissioners conducted their business openly and also provided an opportunity for public comments. The World Privacy Forum was selected to provide a public comment, which focused on the need to update the Health Breach Notification Rule.

Mar 03 2021

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

New Report: Risky Analysis: Assessing and Improving AI Governance Tools

We are pleased to announce the publication of a new WPF report, “Risky Analysis: Assessing and Improving AI Governance Tools.” This report sets out a definition of AI governance tools, documents why and how these tools are critically important for trustworthy AI, and where these tools are around the world. The report also documents problems in some AI governance tools themselves, and suggests pathways to improve AI governance tools and create an evaluative environment to measure their effectiveness. AI systems should not be deployed without simultaneously evaluating the potential adverse impacts of such systems and mitigating their risks, and most of the world agrees about the need to take precautions against the threats posed. The specific tools and techniques that exist to evaluate and measure AI systems for their inclusiveness, fairness, explainability, privacy, safety and other trustworthiness issues — called in the report collectively AI governance tools – can improve such issues. While some AI governance tools provide reassurance to the public and to regulators, the tools too often lack meaningful oversight and quality assessments. Incomplete or ineffective AI governance tools can create a false sense of confidence, cause unintended problems, and generally undermine the promise of AI systems. The report contains rich background details, use cases, potential solutions to the problems discussed in the report, and a global index of AI Governance Tools.
National IDs Around the World — Interactive map

About this Data Visualization: This interactive map displays the presence...
Report: From the Filing Cabinet to the Cloud: Updating the Privacy Act of 1974

This comprehensive report and proposed bill text is focused on the Privacy Act of 1974, an important and early Federal privacy law that applies to the government sector and some contractors. The Privacy Act was written for the 1970s information era -- an era that was characterized by the use of mainframe computers and filing cabinets. Today's digital information era looks much different than the '70s: smart phones are smarter than the old mainframes, and documents are now routinely digitized and stored and perhaps even analyzed in the cloud, among many other changes. The report focuses on why the Privacy Act needs an update that will bring it into this century, and how that could look and work. This work was written by Robert Gellman, and informed by a two-year multi-stakeholder process.