Public Comments

WPF filed two sets of comments with the US Department of Commerce regarding the MultiStakeholder Process and the privacy topics to be taken up. The first set of comments were WPF’s formal filing of the joint Civil Society MultiStakeholder Principles on behalf of WPF and the American Civil Liberties Union, Center for Digital Democracy, Consumer Action, Consumer Federation of America, Consumers’ Union, Consumer Watchdog, Electronic Frontier Foundation, National Consumers’ League, Privacy Rights Clearinghouse, and US PIRG. The second set of comments were WPF’s own comments to the Department. WPF urged the Department to employ a fair process, choose focused topics, and to apply the full range of the Consumer Privacy Bill of Rights to each topic.

The World Privacy Forum appreciates the opportunity to comment on the issue of facial recognition pursuant to the FTC Face Facts Workshop held on December 8, 2011. [1] The World Privacy Forum spoke on Panel 4 of the workshop, and those comments are already on the record. In these written comments, we would like to submit several key documents for the record and reaffirm several ideas from the workshop. The documents we are including as part of these comments include the World Privacy Forum’s groundbreaking report on digital signage, The One Way Mirror Society. Also included as part of these comments are the consensus privacy principles for digital signage installations that were signed by the leading US consumer and privacy groups.

01/30/2012 Consumer financial protection — WPF filed comments with the Consumer Financial Protection Bureau today asking it to make its consumer complaints database available for research.

The World Privacy Forum appreciates the opportunity to submit comments to the Consumer Financial Protection Bureau’s (CFPB) proposed policy statement about the CFPB’s proactive disclosure of credit card complaint data. The proposed statement appeared in the Federal Register on December 8, 2011 at 76 Federal Register 76628, http://www.gpo.gov/fdsys/pkg/FR- 2011-12-08/pdf/2011-31153.pdf and at https://www.federalregister.gov/articles/2011/12/08/2011-31153/disclosure-of-certain-credit- card-complaint-data.

Facebook — In response to the FTC’s proposed settlement with Facebook over the company’s multiple privacy violations, the World Privacy Forum has asked the FTC to make key changes. “We applaud the FTC for its work on the Facebook case,” said executive director Pam Dixon. “We support many parts of the settlement. However, we urge the FTC to provide full redress for affected consumers by rolling back the privacy controls to the 2009 defaults, and we also urge the FTC to follow the 2004 Gateway Learning, Corp. precedent and require Facebook to disgorge profits they made from violating their privacy policy retroactively.” The comment period is open to the public until December 30.