Public Comments

Feb 24 2021

WPF comments on European Commission proposal for new Health Authority

The European Commission has proposed the creation of a new European Health Emergency Preparedness and Response Authority, HERA. WPF provided comments regarding the proposal, urging the Commission to ensure from the outset that HERA will fulfill its mission with a focus on data interoperability and will include specific data governance and protection measures that will analyze

Jan 12 2021

FTC proposes precedent-setting face recognition settlement: photo app company must delete consumers’ photos and the algorithmic models it developed using the photos

The FTC has proposed a crucially important settlement with a photo app developer, Everalbum Inc., which the FTC says “deceived consumers about its use of facial recognition technology and its retention of the photos and videos of users who deactivated their accounts.” The proposed FTC settlement will require the company to obtain consumers’ express consent

Oct 21 2019

WPF advises SEC regarding data risk factors and disclosures

The World Privacy Forum advised the SEC in comments today regarding the SEC proposal to modernize the description of business, legal proceedings, and risk factor disclosures pursuant to Regulation S-K. In its notice, the SEC described risk from environmental regulation as material to companies. In its comments to the SEC, WPF noted that privacy and

Jan 28 2019

WPF responds to HHS and urges it to keep privacy protections in HIPAA strong

WPF has written to the US Department of Health and Human Services advising them on their Request for Information (RFI) about possible changes to HIPAA privacy and security protections. The RFI has a number of suggestions that, should they become part of a formal proposal, would significantly weaken HIPAA privacy protections.

Dec 29 2018

WPF advises FTC regarding privacy frameworks and knowledge governance; files key comments

The World Privacy Forum has submitted a set of key comments to the US Federal Trade Commission regarding privacy frameworks and governance. The comments introduce the idea of knowledge governance and propose frameworks that will work to solve the serious privacy challenges we face in complex data ecosystems.

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

About this Data Visualization: This interactive map displays the presence...
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.