Public Comments

WPF asks Treasury to get consumers’ consent before checking their credit reports

Financial privacy – Privacy Act — The World Privacy Forum filed comments today urging the U.S. Treasury Department to obtain consumers’ consent before checking their credit reports. Consumers who participate in the government’s Home Affordable Modification Program (HAMP) — an Obama administration program created to help consumers renegotiate their mortgages so they can keep their homes — must allow the Federal Government to check their credit reports without first obtaining consent. This procedure sets a negative precedent, and is at odds with consumer expectations of privacy. The Treasury gave itself this power in an obscure set of “Routine Uses” in a Privacy Act notice published along with the proposed system of records for the program. The World Privacy Forum has objected to this, and has filed detailed comments with the Treasury about the lack of consumer consent. The public comment period on this program is open until September 4, 2009.

Public Comments: August 2009 – WPF asks Treasury to get consumers’ consent before checking their credit reports

The World Privacy Forum filed comments today urging the U.S. Treasury Department to obtain consumers’ consent before checking their credit reports. Consumers who participate in the government’s Home Affordable Modification Program (HAMP) — an Obama administration program created to help consumers renegotiate their mortgages so they can keep their homes — must allow the Federal Government to check their credit reports without first obtaining consent. This procedure sets a negative precedent, and is at odds with consumer expectations of privacy. The Treasury gave itself this power in an obscure set of “Routine Uses” in a Privacy Act notice published along with the proposed system of records for the program. The World Privacy Forum has objected to this, and has filed detailed comments with the Treasury about the lack of consumer consent. The public comment period on this program is open until September 4, 2009.

Public Comments: August 2009 – WPF files comments on government use of web tracking technologies

The World Privacy Forum filed comments with the Office of Management and Budget regarding its proposal to begin to allow the use of tracking cookies on government web sites. The proposal was published in the Federal Register, and outlined a three-tiered plan for how web tracking technologies might be used. The Forum’s comments focused on methods of opt-out, data retention, secondary use, user authentication, new tracking technologies such as Flash cookies, and the need for new opt-out mechanisms. The Forum also urged the federal government to not allow third party tracking of consumers’ use of government web sites, and to guard against any discrimination against consumers who do not want to be tracked.

World Privacy Forum files comments on government use of web tracking technologies

Online privacy and government web sites — The World Privacy Forum filed comments with the Office of Management and Budget regarding its proposal to begin to allow the use of tracking cookies on government web sites. The proposal was published in the Federal Register, and outlined a three-tiered plan for how web tracking technologies might be used. The Forum’s comments focused on methods of opt-out, data retention, secondary use, user authentication, new tracking technologies such as Flash cookies, and the need for new opt-out mechanisms. The Forum also urged the federal government to not allow third party tracking of consumers’ use of government web sites, and to guard against any discrimination against consumers who do not want to be tracked.

Public Comments: June 2009 – WPF files comments with the FTC regarding proposed rules for health care-related data breaches

The World Privacy Forum filed extensive comments with the Federal Trade Commission today regarding its notice of proposed rulemaking for data breaches of information containing actual health care information or health care-related information. The FTC rulemaking will apply to a variety of record holders, especially vendors of personal health records. The Forum supported much of the FTC’s proposed rulemaking, finding the rulemaking generally thoughtful and careful. In some areas, the Forum urged the FTC to narrow and further define and strengthen the proposed rule. The World Privacy Forum urged the FTC to tighten language around scope, the definition of “personal health record,” law enforcement delays of consumer notification, and urged the FTC to further clarify the definition of what falls under the category of “de-identified data.” Citing the research of Dr. LaTanya Sweeney and others, the Forum urged the FTC to require commercial companies and others holding health care data that has been partially de-identified to still report those breaches to the FTC and the public, and to monitor for re-identification.