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Public Comments: February 2009 – DMV proposes a major policy shift to biometric systems

On January 14, 2009, the DMV issued a Section 11 (2008 Budget Act) letter to the Legislature stating its intent to change the terms of its driver license and id card contract – including the use of biometric systems including facial recognition scans and biometric thumbprints on people seeking driver’s licenses and ID cards. Unless the Joint Legislative Budget Committee objects within 30 days, the contract with the vendor will take effect.

Security Freeze Page updated with new states

Security freeze — More than 45 states now have credit freeze laws, sometimes called security freeze laws. The World Privacy Forum security freeze page discusses what a security freeze is, who can place a freeze, and is newly updated with links to state-by-state laws and when available, tips for consumers from the relevant Attorney General web site.

Public Comments: May 2008 – Proposed changes to FERPA don’t protect student and parent privacy

FERPA comments: WPF is concerned about the U.S. Department of Education’s proposed changes to its FERPA regulations, FERPA standing for the Family Educational Rights and Privacy Act. FERPA is a significant regulation that controls how students’ school records and “directory” information may be shared. The proposed regulations have one item the WPF is supporting, which is that SSNs are not considered part of the directory information. However, other aspects of the proposed regulation still need work to adequately protect students’ and parents’ privacy interests. The WPF commented in particular that schools should not be allowed to request and then store a full tax refund from parents in order to prove students’ eligibility. The Forum also requested that students’ electronic identifiers are not included in the definition of directory information. One area of substantial concern is that the Department of Education has not expressly provided that students who opt-out of having their directory information shared should not be penalized for opting out. Currently, the proposed regulations may be read to suggest that schools may be able to deny benefits, services, or even required activities to students who have exercised the right to opt-out of the publication of directory information..

Public Comments: February 2008 – WPF, NCLC, and Consumer’s Union file extensive comments regarding accuracy of credit reports

The NCLC, Consumer’s Union, and the World Privacy Forum filed extensive joint comments today regarding the proposed rulemaking, Procedures to Enhance the Accuracy and Integrity of Information Furnished to Consumer Reporting Agencies under Section 312 of the Fair and Accurate Credit Transactions Act. The results of the proposed rulemaking will have a significant impact on how the accuracy of credit reports is defined for consumers, and will have a substantive influence over how consumers may handle credit report disputes directly with those who furnish information for the reports.