CDT Comment to House E&C Argues Federal Comprehensive Privacy Framework Should Protect Against Harms and Bolster Consumer Trust
CDT submitted these comments in response to the House Energy & Commerce Committee Privacy Working Group’s request for information (RFI) regarding a federal comprehensive privacy and security framework. We appreciate the opportunity to comment and the committee’s desire to gather more information from stakeholders about their privacy viewpoints and evidence of data practices and their harms.
In our comments, we urge the Working Group to build upon the significant amount of work done in the past several years to achieve bipartisan consensus on key elements of a federal privacy framework. We highlight that any effective federal privacy law must place limits on companies’ collection, use, processing, and sharing of data to protect individuals from harm. These harms include fraud and other economic injury, discrimination, reputational harm, harassment, and government surveillance that circumvents the Fourth Amendment and other legal protections. Because many of these risks increasingly arise from the use of artificial intelligence (AI) such as in automated decision-making systems, an effective 21st century privacy framework should account for AI. It should also provide meaningful transparency and require companies to regularly examine their data practices to mitigate risks to consumers. Protecting privacy will bolster consumer trust in our increasingly data-centric economy and thereby enable greater innovation.
