Public Comments

Jun 01 2018

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

May 09 2018

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.

Jan 03 2017

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

Oct 26 2016

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

Oct 19 2016

WPF asks US DOJ to retain Privacy Act fairness standards in new system of records

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

New Report – Without Consent: An analysis of student directory information practices in U.S. schools, and impacts on privacy

Without Consent is the first major benchmarking privacy report to examine school directory information practices and related privacy issues in a multi-year study across more than 5,000 schools at the primary, secondary, and postsecondary levels. The research found troubling and challenging student privacy problems that need to be urgently addressed. The report contains extensive findings and recommendations regarding student privacy, and includes best practices, sample forms, and resources for schools, parents, and students.
Patient’s Guide to HIPAA: How to Use the Law to Guard your Health Privacy

Download PDF Download ePub Donate Credits → Version 2.0...
Report: The Geography of Medical Identity Theft

This new WPF report finds that medical identity theft is still a crime that causes great harms to its victims, and that it is growing overall in the United States; however, there’s a catch. The national consumer complaint data suggests that the crime is growing at different rates in different states and regions of the US, creating medical identity theft “hotspots.” These hotspots are important for patients, policymakers, and healthcare stakeholders to know about so as to address potential risks.