Public Comments

WPF Comments: Access to the CFPB consumer complaint database is vital to understanding and analyzing identity theft in the US

WPF has urged the CFPB to continue to maintain its consumer complaint database and make complaints available to the public. The CFPB is considering multiple potential changes to its consumer complaint database, including reducing access, among other potential changes. In its comments, WPF explained how CFPB consumer complaint data has been vital to our ability to

WPF comments on the DHS External Biometric Records database

The World Privacy Forum has submitted detailed comments on the US Department of Homeland Security’s External Biometric Records database (EBR database), which DHS describes as a large biometric and demographic database drawn from foreign and domestic sources. WPF has a number of concerns about the proposal, including that the EBR database is slated to be exempted from

Public Comments: WPF comments on proposed revised consent decree re: Uber; requests FTC to hold workshop to determine standards for privacy assessments

In comments to the FTC regarding a proposed revised consent decree with Uber Technologies, Inc., WPF urged the FTC to clarify what the term “assessment” means in the context of a consent decree with a company. The comments note that the requirement for an assessment is not the same as the requirement for an audit.

WPF supports proposed changes to drop SSNs from some appellate forms

The World Privacy Forum commented in support of a proposed change to the federal rules of practice and procedure. The change would eliminate the requirement to include the last four digits of a litigant’s Social Security Number on Appellate Form 4, which is used by petitioners seeking to proceed in forma pauperis. “When we can reduce reliance on

New proposed Privacy Act guidance: Federal Agency Responsibilities for Review, Reporting, and Publication under the Privacy Act

The World Privacy Forum submitted comments today on an important proposal from the US Executive Office of the President, Office of Management and Budget regarding a circular directing agencies how to write, post, review, and generally handle Privacy Act notices. The proposal, called Circular A-108 Federal Agency Responsibilities for Review, Reporting, and Publication under the