The modern permanent record is a set of disparate bits of information about you that can be pieced together from online, offline, and other data sources to create a mosaic of your likes, dislikes, characteristics, finances, education, buying habits, eating habits, health conditions, and more. This mosaic can contain segments that are stubbornly difficult to remove or change; we call this the “modern permanent record.”
Social networks — In the wake of Europe’s Article 29 Working Party Opinion on Social Network Providers adopted in June, the Federation of German Consumer Organizations (VZBV) has sent out warning letters to five social networking providers in Germany, including Facebook and MySpace. The letters focus on the excessive rights the companies allow themselves in their respective Terms of Use agreements, and on shortcomings in the privacy policies. VZBV is comprised of 41 German consumer associations.
Consumer resource — We have updated the World Privacy Forum’s state-by-state guide on how to place a credit, or security, freeze. Only a few states are lacking a security or credit freeze law now.
Genetic Privacy | GINA — The World Privacy Forum filed comments on the proposed regulations on the Genetic Information NonDiscrimination Act, or GINA. The comments request that the Equal Opportunity Employment Commission close down several potential loopholes in consumer protection in the proposed regulations. The Forum specifically asked the EEOC to consider curtailing the amount of commercially available information employers could access about employees, for example, through marketing databases. WPF also requested that those covered under GINA be required to maintain audit trails in certain circumstances, and urged that wellness programs be structured in such a way so as to prevent information leakage through billing and other activities.
Data broker opt out issue — The World Privacy Forum sent a letter to the Federal Trade Commission asking it to look into four companies offering online consumers the ability to opt out, then asking those consumers to use a variety of postal-mail-based methods to do so.
Biometrics and ID — The California DMV (Division of Motor Vehicles) has proposed, through an expedited 30- day process, that it begin taking detailed facial scans of drivers and storing the scans in a state-wide database. This change, among other proposed DMV changes, represents a substantial policy shift for the state of California. The World Privacy Forum has urged that this process goes through normal legislative procedures so that there is adequate time for public input and for formal hearings.