CDT Comments to National Telecommunications and Information Administration (NTIA) on Advancing Consumer Privacy
9 November 2018
Submitted via email to privacyrfc2018@ntia.doc.gov
National Telecommunications and Information Administration
U.S. Department of Commerce
1401 Constitution Avenue NW, Room 4725
Washington, DC 20230
RE: Docket No. 180821780-8780-01
CDT respectfully submits these comments in response to the request for public comment from the National Telecommunications and Information Administration (NTIA) on how to advance consumer privacy.
CDT advocates for a strong federal baseline privacy law and believes that any administration proposal must have a legislative component at its foundation. Meaningful commercial privacy protection requires common standards and protections across industries, limits on the use of sensitive data, and rigorous enforcement. Importantly, a federal solution must be carefully scoped to provide one national standard for data protection without undermining state action that does not directly address consumer privacy in the digital ecosystem. We appreciate the NTIA’s recognition that companies should embrace longstanding Fair Information Practice Principles (FIPPs), as well as internal accountability and risk management efforts, but the administration must advance a legislative proposal that additionally prohibits intrusive and unfair data collection and use.
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