The World Privacy Forum appreciates the opportunity to comment on the issue of facial recognition pursuant to the FTC Face Facts Workshop held on December 8, 2011. [1] The World Privacy Forum spoke on Panel 4 of the workshop, and those comments are already on the record. In these written comments, we would like to submit several key documents for the record and reaffirm several ideas from the workshop. The documents we are including as part of these comments include the World Privacy Forum’s groundbreaking report on digital signage, The One Way Mirror Society. Also included as part of these comments are the consensus privacy principles for digital signage installations that were signed by the leading US consumer and privacy groups.

01/30/2012 Consumer financial protection — WPF filed comments with the Consumer Financial Protection Bureau today asking it to make its consumer complaints database available for research.

The World Privacy Forum appreciates the opportunity to submit comments to the Consumer Financial Protection Bureau’s (CFPB) proposed policy statement about the CFPB’s proactive disclosure of credit card complaint data. The proposed statement appeared in the Federal Register on December 8, 2011 at 76 Federal Register 76628, http://www.gpo.gov/fdsys/pkg/FR- 2011-12-08/pdf/2011-31153.pdf and at https://www.federalregister.gov/articles/2011/12/08/2011-31153/disclosure-of-certain-credit- card-complaint-data.

01/23/2012 GPS tracking | United States v. Jones — The US Supreme Court unanimously ruled that police must get a warrant before using GPS devices to track criminal suspects. This case was narrow and dealt specifically with a GPS device physically attached to a suspect’s vehicle. The concurring opinion of Justice Sotomayor points out that the subtler issues of digital era tracking were not dealt with in this case, for example, cell phone tracking, web site tracking, etc. She wrote: “More fundamentally, it may be necessary to reconsider the premise that an individual has no reasonable expectation of privacy in information voluntarily disclosed to third parties. E.g., Smith, 442 U. S., at 742; United States v. Miller, 425 U. S. 435, 443 (1976).” She continued: “This approach is ill suited to the digital age, in which people reveal a great deal of information about themselves to third parties in the course of carrying out mundane tasks.”

Stop SOPA & PIPA —- The World Privacy Forum is deeply concerned about the profound, far-reaching privacy consequences of two bills, SOPA and PIPA. The bills have many negative aspects. In terms of the privacy impacts, one of the serious consequences is that the right to create and use anonymization software tools would be essentailly