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
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.
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
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
The World Privacy Forum filed a pair of comments about a US Department of Justice proposal regarding treatment of insider threat records at the FBI. Our first comments respond to a Systems of Records notice, our second comments respond to a Notice of Proposed Rulemaking on the same issue. In our first set of comments