CDT Comments to FTC: Boosting Privacy by Design and Data Security Guidance

CDT submitted these comments to the Federal Trade Commission as part of a series of hearings to explore how the competition and consumer protection landscape has shifted since the 1995 Pitofsky hearings.

The following comments address (1) how the Commission can use its Section 5 authority to address the role of design in privacy, (2) the Commission’s rulemaking and enforcement under COPPA, (3) the tools and resources necessary for the Commission to effectively hold industry accountable, and (4) recommendations for developing the Commission’s data security regime.


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