Public Comments

Public Comments: June 2006 – Medicaid Program and State Children’s Health Insurance Program Systems Notice

The World Privacy Forum submitted comments to the Centers for Medicare & Medicaid Services requesting that it amend a Systems of Records Notice to address an oversight and address other privacy issues. The Forum requested that CMS add a reference in the system notice to Executive Order 13181 of December 20, 2000, “To Protect the Privacy of Protected Health Information in Oversight Investigations.” The Forum also requested that the routine uses be revised to reflect the HIPAA requirements as appropriate when the disclosures involve HIPAA records.

Public Comments: May 2006 – US Civil Society Organizations (CSO)

EPIC filed comments with the Department of Commerce, which the World Privacy Forum joined. The Office of Technology and Electronic Commerce solicited comments on the development and implementation on “cross-border privacy rules” in the Asia PacificEconomic Cooperation Group (APEC). Seven groups submitted the comments on behalf of civil society organizations (CSO) in the United States concerned about privacy in order to urge the strengthening of privacy rules in the Asia Pacific Economic Cooperation Group.

Public Comments: March 2006 – IRS on Tax Information Sharing

The proposed changes to the regulations represent an important effort to increase taxpayers’ awareness of what is done with their personal information. However, the updated regulations fail to adequately safeguard taxpayer privacy because they neglect to protect information once it is disclosed, allow consent that is less than voluntary, and carry penalties that are not harsh enough to ensure tax return preparers obey the law.

Public Comments: January 2006 – Identity theft survey

The World Privacy Forum submitted comments in response to the Federal Trade Commission’s request for feedback on its upcoming identity theft survey. The FTC identity theft survey is one of the most quoted surveys on the subject. The World Privacy Forum requested changes and clarifications to the survey, including adding questions about security breach notices and clarifying existing questions about medical identity theft, among other issues.