Public Comments

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.

Oct 26 2018

FTC announces expanded settlement with Uber, WPF comments included

The FTC finalized an expanded settlement with Uber, Inc. regarding the company’s data security practices. According to the FTC complaint, in the midst of the Commission’s original investigation, Uber experienced a second serious breach and waited more than a year after learning of the breach before informing the public or the Commission. The World Privacy Forum

Jun 04 2018

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

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.
COVID-19 and HIPAA: HHS’s Troubled Approach to Waiving Privacy and Security Rules for the Pandemic

The COVID-19 pandemic strained the U.S. health ecosystem in numerous ways, including putting pressure on the HIPAA privacy and security rules. The Department of Health and Human Services adjusted the privacy and security rules for the pandemic through the use of statutory and administrative HIPAA waivers. While some of the adjustments are appropriate for the emergency circumstances, there are also some meaningful and potentially unwelcome privacy and security consequences. At an appropriate time, the use of HIPAA waivers as a response to health care emergencies needs a thorough review. This report sets out the facts, identifies the issues, and proposes a roadmap for change.