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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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CDT Opposes Reconsideration of FCC Broadband Privacy Rules

The Commission created a balanced set of rules that give consumers meaningful control over their personal information while maintaining flexibility for telecommunications companies to use data for improving services, crafting new technologies, and advertising. Petitioners’ efforts to weaken the rules are not supported by the record and contradict the Commission’s own guidance. They would expose internet users to unnecessary privacy and data security risks and undermine consumer trust in the broadband market.

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Data Brokers, Don’t Help Build Muslim Registry or Facilitate Mass Deportations

Because of the risks that big data could be exploited to violate human rights of Muslims, migrants or others in the United States, the undersigned 17 organizations are sending letters to nearly 50 data brokers in the United States. We are calling on them to disclose whether they have refused requests to share data with the government, what steps they take to make sure their activities do not lead to human rights abuses, and to take the following pledge.

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