Privacy questions arise due to the volume and sensitivity of health data generated by consumer-focused apps, devices, and platforms, including the potential analytics uses that can be made of such data. Transparency about data practices is essential not just as a fundamental element of privacy, but is also key to engendering consumer trust, which in turn is critical to the adoption of these services. Without trust, consumers will resist using apps or devices and the industry as a whole will suffer. Overall, transparency practices should be guided by the principle that the consumer should not be surprised. The more unexpected or potentially objectionable a data collection or usage is, the greater the obligation to explain it to consumers.
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Washington is experiencing a “Privacy Spring”: the online privacy debate has been rejuvenated and for the first time in over a decade, privacy is back on the policy table. Both the Federal Trade Commission (FTC) and the Department of Commerce have issued reports setting out robust frameworks for privacy protections, bills are being introduced in Congress, and the Obama Administration has announced support for baseline privacy legislation. Not surprisingly, teenagers have become a focal point of the current debate over online privacy, tracking, and advertising. In this piece, I argue that concerns about teen privacy will best be addressed through a strong comprehensive privacy law that requires adherence to Fair Information Practices by all commercial entities, including advertisers, that collect and use personal data.
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The comments here respond to the questions posed in the Federal Trade Commission’s draft privacy report. CDT believes the draft report provides a strong foundation for a privacy protection framework and we applaud the FTC’s excellent work. We are especially pleased to see that the FTC has embraced the full range of the Fair Information Practice Principles and recommended…
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