Public Comments

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

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. 

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

WPF comments on European Commission proposal for new Health Authority

The European Commission has proposed the creation of a new European Health Emergency Preparedness and Response Authority, HERA. WPF provided comments regarding the proposal, urging the Commission to ensure from the outset that HERA will fulfill its mission with a focus on data interoperability and will include specific data governance and protection measures that will analyze

FTC proposes precedent-setting face recognition settlement: photo app company must delete consumers’ photos and the algorithmic models it developed using the photos

The FTC has proposed a crucially important settlement with a photo app developer, Everalbum Inc., which the FTC says “deceived consumers about its use of facial recognition technology and its retention of the photos and videos of users who deactivated their accounts.”  The proposed FTC settlement will require the company to obtain consumers’ express consent