CDT Comments to FTC on Competition and Consumer Protection in 21st Century
CDT respectfully submits these comments in response to the request for public comment from the Federal Trade Commission on how to advance consumer privacy.
CDT advocates for a strong federal baseline privacy law; in the absence of this, we have argued for the Commission to more aggressively exercise its unfairness authority under Section 5 of the FTC Act to address the inadequacies of user controls and privacy self-management and information asymmetries that limit an individual’s ability to make informed decisions about privacy. Instead, since taking on the mantle of privacy enforcer twenty years ago, the FTC has largely relied on its deception authority under Section 5 to police data privacy matters. Privacy enforcement as “enforcing privacy promises” has not provided sufficient privacy protections for individuals.
Our comments largely detail CDT’s thinking of what a federal privacy framework should look like in response to the FTC’s query on legal framework. However, we also respond to several of the general questions posed by the Commission.
CDT and Partners Urge Passage of the California Location Privacy Act of 2025 (AB 322)
Location data is particularly sensitive, and when collected across time it can reveal a broad range of intrusive insights such as medical conditions, sexual orientation, political activities, and religious beliefs.
CDT and Allies Urge FCC Not to Violate Privacy of Cell Phone Buyers
CDT and EPIC led a coalition of 15 organizations in urging the FCC not to require phone companies to collect government IDs, physical addresses, and alternate phone numbers from every phone subscriber in the country.
As Brussels starts emptying for the summer, the risks of frontier AI models continue to capture the attention of policymakers as a key chapter of the AI Act becomes enforceable, and disclosure rules around the use of AI systems and AI-generated content are further clarified.
