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 without commensurate requirements for not selling, sharing, or otherwise using those records 
  • The narrowness of some of the technical language around soundboard technology in the proposal. We encourage the addition of broader terms such as digital soundboards.
  • The proposal does not incorporate the modern uses of voice biometrics in its analysis of telemarketing activities. This is an extremely important analysis to add to the rule. The proposal could be as simple as requiring telemarketing companies to notify consumers of the use of such technologies, and to keep records of what technologies were used, why, and when. 

We have urged the Commission to do more in these areas, which we discuss in these comments.

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