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CDT 2016 Annual Report

CDT’s team contributed to so many of the critical tech and internet policy debates and advancements in 2016. We look forward to working with you to shape a world where technology advances democratic values and empowers us all to enjoy our fundamental rights.

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RE: Comments on NHTSA Notice of Proposed Rule for FMVSS No. 150, V2V Communications (Docket No. NHTSA-2016-0126)

CDT and four top cryptography and security experts submitted the following comments in response to the National Highway Traffic Safety Administration’s (NHTSA) notice of proposed rulemaking to establish a new Federal Motor Vehicle Safety Standard (FMVSS), No. 150, which intends to mandate and standardize vehicle-to-vehicle (V2V) communications for new light vehicles. Our comments highlight our concern that NHTSA’s proposal standard may not contain adequate measures to protect consumer privacy from third parties who may choose to listen in on the Basic Safety Message (BSM) broadcast by vehicles.

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Rethinking Privacy Self-Management and Data Sovereignty in the Age of Big Data

This paper advances the idea that the rise of large data collection and processing, also known as big data, has challenged the validity of data-protection regimes founded on ideals of individual control. With a focus on data sovereignty, it investigates concepts able to meet the requirements of big-data technologies, while also offering guidance for future policy regimes.

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Comments Re: National Emergency Address Database Privacy and Security Plan PS Docket No. 07-114

In January 2015, CDT joined with other public advocacy organizations to express concerns about the privacy impact of the NEAD. We cautioned that users of networked devices likely do not expect that information about their personal devices and physical address will be stored in a national database that is accessible to multiple parties. In those comments, we offered several recommendations for protecting user privacy including strong limits on third-party access to the database and opt-out mechanisms for individuals.CDT is pleased that the draft NEAD Privacy and Security Plan appears largely to address these concerns. We write now to highlight several aspects of the NEAD Platform that protect privacy and security, and suggest how the plan’s practices might evolve in the future.

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Joint Open Letter on Article 13 of EU Commission’s Copyright Proposal

CDT has signed a joint open letter together with other civil society organisations expressing concern over the European Commission’s copyright proposal, in particular its upload filter obligation provision. Article 13 of the proposal forces internet intermediaries to use content identification technology to prevent users from uploading unlicensed copyrighted content. This is a dramatic erosion of the liability protections in the E-Commerce Directive and would negatively impact the free speech of citizens who would see their content blocked even if it is a legal use of copyright content under a copyright exception.

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Comments to the TRAI in Response to the Consultation Paper on Net Neutrality

CDT thanks the Telecom Regulatory Authority of India for its thorough and thoughtful consideration of the principles supporting the concept of net neutrality as well as the practical issues with implementing a regulatory scheme to preserve an open internet. CDT has participated in the TRAI’s consultation on differential pricing and the pre-consultation on net neutrality and now respectfully submits these comments in response to the questions raised in the TRAI’s Net Neutrality Consultation.

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CDT Comments to the NTIA on Fostering the Advancement of the Internet of Things

Though it is likely that the Federal Trade Commission will continue to lead on privacy policy and enforcement, CDT recommends that the NTIA and Department of Commerce continue their ongoing efforts to engage stakeholders and to pursue consensus-based global standards, starting from the premise that the privacy challenges raised by the IoT are novel. The Department is well positioned to highlight efforts within industry to promote privacy, which includes addressing basic Fair Information Practice Principles and adopting privacy by design across the full lifecycle of IoT devices, products, and services.

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Coalition Letter to Secretary Kelly Opposing Collection of Passwords at the Border

A coalition of human rights and civil liberties organizations and trade associations wrote to DHS Secretary Kelly in response to his statement at the House Homeland Security Committee hearing, that the Department of Homeland Security would consider requiring visa applicants to provide log-in information (passwords or other credentials) for their social media accounts.

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