Public Comments: WPF files comments urging the SEC to protect asset-level data privacy of consumers

The World Privacy Forum submitted comments to the Securities and Exchange Commission today requesting that the SEC do more to protect the privacy of consumers’ asset information. Asset information — the financial information attached to mortgages, car loans, and other consumer borrowing activities– is very attractive to the consumer data industry. We would be happier with the current SEC proposal if it were practical to keep all sensitive asset-level data under the direct control of the Commission or, perhaps, the Consumer Finance Protection Bureau. Direct involvement by a federal agency, while no guarantee of a better outcome for data subjects, would provide better and clearer accountability for maintenance of the data as well as the possibility of meaningful enforcement.

The comments outline concerns that the Fair Credit Reporting Act cannot serve as an umbrella of protection for asset-level data. Some of this asset information will reveal directly a most desired class of data, namely actual income data for individuals and households. The consumer data industry sometimes has approximate income data, limited salary data, and other proxies for income, but complete income data can be hard to obtain. Asset-level data is highly desirable, and highly desirable data will attract consumer data industry users as well as identity thieves.

Consumers who have their specific asset level data revealed by the SEC need certainty of privacy protections.

In the comments, WPF urged the SEC to use Fair Information Principles as a guidepost, as well as specifically use the tool of detailed data use agreements to control information use after collection and to specifically protect detailed consumer asset information from becoming fodder for use in eligibility. credit, insurance, consumer scoring, or other purposes.

Links:

Read the WPF comments on asset data privacy (PDF, 8 pages)

Posted April 21, 2014 in Financial Privacy, Public Comments, Public Policy, Public Records, SEC, US Securities and Exchange Commission

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

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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.

Public Comments: WPF files comments urging the SEC to protect asset-level data privacy of consumers

Links:

Read the WPF comments on asset data privacy (PDF, 8 pages)