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

National IDs Around the World — Interactive map

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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.