FTC White Paper Responses

This is a data page containing the text of all the responses to the FTC White PaperProtecting Consumer Privacy in an Era of Rapid Change: A Proposed Framework for Business and Policymakers“, preliminary FTC staff report, December 2010. It is reformatted here for convenience in reading, searching, and downloading the linked PDF documents.

See our analysis blog post about the FTC responses and spreadsheet with additional data.

DoC: indicates document(s) that the same organization or individual submitted in response to the Department of Commerce Green Paper, and geo indicates a submission from the geospatial industry – the two are exclusive except for one case, MAPPS.

Submission Number: 00002

Received:12/1/2010 1:04:01 PM
Commenter: AmarjeetGarewal
State:California
I support “Do Not Track” mechanism

Submission Number: 00003

Received:12/1/2010 1:09:47 PM
Commenter: JohnBlumel
State:New York
The only system that will prevent continued invasion of privacy by companies that profit through trafficking in personal data is one where it is illegal to collect data without consent. Opt-out simply won’t work because there’s no practical and effective technological method for implementing it. Any opt-out system would necessarily involve forcing citizens to give up additional information that tracking companies may not even have no, allowing them to “inadvertently” track users with greater precision and collect even more information than they do now. Opt-out is also totally unenforceable as there is no practical way to know whether tracking companies are in compliance or not.

Submission Number: 00004

Received:12/1/2010 1:38:52 PM
Commenter: RohitNallapeta
State:California
I applaud the FTC for a great step towards privacy. I think this should be an option and a choice consumers deserve. The real issue however is companies that install cookies without permission and I am hoping this will be curtailed through this mechanism. I think marketers and business stands to benefit as people who allow tracking are more willing customers. This law will also lead to innovation in the online ad industry.

Submission Number: 00005

Received:12/1/2010 2:03:03 PM
Commenter: DiPalma
State:District of Columbia
I applaud the FTC in tackling an issue most Internet using Americans fear, which is the pervasive use of private/personal data without the individual’s explicit approval. The industry will try to convince Americans that this act is pointless and should be driving by the industry itself. However, there is a precedent that the industry can, but will not effectively create nor implement this type of safeguard. Microsoft’s Internet Explorer 8 has such a feature called InPrivate Filtering. This feature should have the option to be permanently set to filter, however, after internal wrangling between programmers and executives, the profiteering executives made the feature an option which would need to be deliberately activated each time the software was opened. I support this measure and hope it would be used to hinder any further data warehousing of our private information.

Submission Number: 00006

Received:12/1/2010 3:18:08 PM
Commenter: BrianLane
Organization:www.propools.com
State:Tennessee
In thinking about, “The proposed report also suggests implementation of a ‘Do Not Track’ mechanism”.

I would like to add that even if it is a “persistent setting on a consumers’ browser” that does not inhibit or restrict the ISP from tracking and reselling such data.

1. In first reading it looks as if the restriction is set to the individual B-2-C sites, such as amazon.com or propools.com. There does not appear to be any language or anything addressing what the ISP does with their customer’s data. Meaning, any ISP can track/measure which websites their customers are browsing to. Then it’s the ISP who can become the reseller of such data to Mail Groups, etc. Then it’s still the same problem as the website doing it, it’s just one step removed.

2. There may be ways in which passing data back to a particular web site may be beneficial and not doing so, harmful to the consumer. For example, if someone were to search for above ground pools and their IP location not be passed back to companies like Google then they would not get the side bar link of http://www.propools.com/Above_Ground_Pools.php which may just happen to be local for them. And this may be what they’re looking for, the just haven’t realized it yet.

Restricting data collection is in part a good thing but also bad, as this is what drives a lot of business and business growth.
If the command to “Not Track” is in the browser, what happens when it’s a household or publicly used computer?
What if one user doesn’t want their data tracked and the other does?
Should individual users have a unique identifier, like an SSN does?

Because the access points to the internet can be many people through a single point, there should be a way to differentiate. Though I don’t have the precise answer, I do have opinion of it.

Just like there’s the National Do Not Call Registry (www.donotcall.gov), a solution may lie somewhere within this type of framework.

I applaud the intent of such an undertaking and would be more than willing to assist in any way I can for the promotion of consumerism and standardized data practices.

I yield my remaining 1778 characters to the consumer. Hah, 1778 What happened then? ;)

Brian

Submission Number: 00007

Received:12/1/2010 3:20:27 PM
Commenter: LornaBethShantz
State:Pennsylvania
Yes! Pursue this!!

Submission Number: 00008

Received:12/1/2010 4:29:04 PM
Commenter: Robert L.Couch
State:Arizona
The FTC should convert this preliminary report to regulation as rapidly as possible. Currently internet users have no recourse and extremely few technical resources to counter internet behavior tracking technologies, even when aware of what is taking place. Most users have no idea they are being stalked in virtual space for private gain by others. Even if an internet user tracking firm tells all users that it will not collect their individual information, how can an individual verify the corporate claim?

My rights to privacy and freedom of movement in virtual space as a law-abiding, individual citizen are being threatened by private companies for their own financial gain, using powerful behavioral tracking technologies under development and now being deployed surreptitously.

If a Government were as a matter of course to collect the kinds of tracking data (I call it financial stalking) on all citizens that internet user behavior tracking firms are now beginning to deploy, there would be a huge public outcry if not actual litigation mounted to stop such interference with private lives. Corporations should not be held less accountable than Government in this regard.

The FTC might also consider how close the legal boundary is and should be between the emerging internet user behavior tracking technologies and the statutory restraints already embodied in law regarding “wiretapping activities.” Corporations may say that they will not disclose personal identity information to the consumers of their tracking technologies. But the deployed technologies will have the ability to collect that information, even if it is not intended to be conveyed to tracking technology clients. Why should a for-profit firm be held to a lesser legal standard than Government regarding data collections that occur without the knowledge of the subjects of the collects?

If individual internet users want or do not mind their internet behaviors being tracked, they can “Opt in” to the technologies on a case by case basis. The default settings in all internet user interfaces should be “OPT OUT.”

Submission Number: 00009

Received:12/1/2010 4:31:50 PM
Commenter: AlanBurch
State:District of Columbia
The proposal makes sense and should be adopted. In writing the rule, the agency should take great care, however, in guarding against the myriad ways that companies might manipulate the choice the consumer will make regarding allowing data collection. For example, the company might conditioning access to certain information or services on the consumer “agreeing” to allow the collection of data. For the rule to be effective, therefore, it should explicitly bar websites from providing any difference in content, services, browsing options, etc., where any difference turns on whether the consumer “agreed” to data collection.

Submission Number: 00010

Received:12/1/2010 4:49:26 PM
Commenter: AlexanderReis III
Organization:Hyundai Research Institute
State:Washington
The tracking of my internet habits and preferences by advertisers and “unknown others” is, in my opinion, no less invasive, nor more acceptable, than government authorities tracking by reading habits at a public library.

I am SICK of seeing ads for “Older singles,” “Penis Enlargement” and hotel chains in Singapore – for no other reason than these invaders seem to have figured out that I am a middle-aged man who once traveled to Hong Kong.

Has anyone considered the impact of this invasion on productivity in the United States and around the world? It slows my work. It stifles my business. It often cripples my computer.

We, the people, should not have to “opt out” of such garbage. Rather, if anyone should truly want this “tracking” to interfere with their business and their online activity, they should be able to exercise their right to “opt in.”

I now purchase all of the television programs I watch from ITunes, to avoid the incessant, insipid drone of commercial fodder. I’m sure they’re probably tracking that, too. What I wouldn’t pay to get these vultures off of my screen, and out of my life.

Sincerely,

Alexander J. Reis III

Submission Number: 00011

Received:12/1/2010 6:25:17 PM
Commenter: MaraGordon
State:California
I’m in favor of a DO NOT TRACK option. I do not believe that web sites, browsers, etc have the right to my browsing habits any more than they have the right to look into the windows of my house. Huffington Post tracks what its members read, but has a STEALTH option.

As for ads being directed towards me, I am often frustrated by the space taken up by what I see as “worthless noise” on my screen. The amount of money being made by companies like Google by hovering over my virtual back is outrageous when I have no say whether I wish to participate or not. I’d rather have less results returned – no paid ads – and no tracking.

If the government wishes to track, they need a warrant. Why not a website?

Submission Number: 00012

Received:12/1/2010 6:58:00 PM
Commenter: thomasWheeler
State:Colorado
i agree that companies should not have the right to collect information while surfing the web

Submission Number: 00013

Received:12/1/2010 7:25:58 PM
Commenter: Jameshenry
State:Florida
This is just another government attack on the free enterprise system. And the government wonders why entrepreneurs are leaving this county in droves.

The Internet exist as it is today because of the money that is made from it. Take away the money made by marketers and it will be the worldwide desert.

FTC stop killing the free enterprise system that has made this country wealthy.

Submission Number: 00014

Received:12/1/2010 8:08:19 PM
Commenter: StephanieMarcus
State:New York
Every time I load a page in my Camino browser, I get a Facebook cookie attached and spying on me.
I do not use Facebook. I don’t have a Facebook account.
I do not want Facebook invading my privacy. I did not give them permission.
I do want DO NOT TRACK laws.
Thanks

Submission Number: 00015

Received:12/1/2010 8:22:16 PM
Commenter: AlboFossa
State:New Mexico
I very much appreciate the FTC’s efforts in this arena. The difficulties I perceive include cases in which one or more of the following apply:

a. multiple computers are used by the same person (our household, for example, has at least three at any given time)

b. a computer is used by more than one person (our household, for example, has two people, each of whom may use any of the multiple computers)

c. a computer has more than one browser installed (our multiple computers have at least five browsers installed; each browser stores cookies in a manner of which other browsers may not be aware)

In addition to the obvious need of acquiring the “good will compliance” of all involved website authors, I hope the above are technical obstacles are matters the FTC is able to keep in mind.

Submission Number: 00016

Received:12/1/2010 9:01:13 PM
Commenter: Russo
State:California
I simply wanted to state my support of a “Do Not Track” system. Thank you for your time.

Submission Number: 00017

Received:12/1/2010 9:07:35 PM
Commenter: davidlyons
State:California
I am in favor of a total “do not track ” policy. I know where I want to shop or browse and I do not need an advertiser to direct me to his product. Knowing that it took forever for my DO NOT CALL privacy option to work, I hope that the FTC will make it simple to get the full effect of DNT. I do consider tracking an intrusion of my privacy because if they can track my movements, the can certainly identify me through my computer and email address. If this effects data collection agencies and changes their bottom line, I am not concerned about that issue. Stopping tracking will effect very few workers since this is largely done by computer robots anyway. If companies go out of business as a result of DNT, that is the nature of provate enterprise.
In the end, it might prove cheaper for consumers since companies pay for advertising and users want to avoid the advertising, so it could be a win-win situation. Product cost would not have to reflect the cost of bypassed advertising.
In any case, any tracking should only be done with MY permission, so I should have the immediate ability to indicate yes or no. It is time to start controlling business practises in all venues. In fact, the business community should have absolutely no say in this matter because it only effects the privacy of on-line users, who should have total say in this matter.
Thank you for allowing me to present my argument AGAINSAT tracking.

Submission Number: 00018

Received:12/1/2010 9:11:20 PM
Commenter: RobertParsons
Organization:US Citizen
State:California
The Do Not Call list is one of the BEST things the US Government has done in my lifetime(50ys), although I still get annoying automated phone spam calls, they are greatly reduced.
If you could effectively do that for the internet, I’m all for it. Please bear in mind that if you outlaw it here, they will use servers in other countries to circumvent domestic provisions.

Increased privacy on social networks would also be nice. Any provisions should be technologically workable form a website design and smartphone capability point of view.
Thank you, Citizen Robert

Submission Number: 00019

Received:12/1/2010 9:25:30 PM
Commenter: Strauss
State:Massachusetts
To Whom It May Concern,

I am writing to offer my comments on the proposed Preliminary FTC Staff Report on “Protecting Consumer Privacy in an Era of Rapid Change: A Proposed Framework for Businesses and Policymakers.” I do not have particular expertise regarding these issues. I express my opinions here as a regular user of the internet and other forms of media.

I would like to voice my initial support for the development and timely implementation of a “do-not-track” option to be offered to consumers. I take issue with anyone who suggests that current industry self-regulation of consumer privacy is anywhere near adequate. This is one area where the free market is simply inadequate. I am fed up with the steady stream of news and opinion pieces over the last few years that encouraged consumers to acquiesce to a new, compromised standard for personal privacy. I, for one, find the current situation unacceptable, and I applaud the draft proposal submitted by the FTC.

Thank you for your consideration.

Submission Number: 00020

Received:12/1/2010 9:36:30 PM
Commenter: MichaelCarnes
State:Utah
I am very much in favor of this proposal. I do understand that many web sites base their business models on such information-gathering. It may be that no harm is intended, but existing practice also shows that these companies change their terms of service with little or no acquiescence by the customers. Data has a habit of living on, and can be put to uses not intended or envisioned by the original collectors. Consumers have every right to limit or prevent gathering of this data.

Submission Number: 00021

Received:12/1/2010 9:50:40 PM
Commenter: Chris
State:Illinois
I strongly SUPPORT the “do not track” list. Just like “do not call”, for privacy reason “do not track” is very important. It gives too much power to companies collecting such information over a person’s behavior. Ultimately such companies (if they do not already know) would know how much a person earns, his family members’ names, income, gender, bank balance, debts, assets, friends, hobbies, jobs and what not. That is too scary.

I would also support “do NOT photograph” to get house/businesses off Google’s street view project.

Thank you.

Submission Number: 00022

Received:12/1/2010 11:16:19 PM
Commenter: AnnetteHendricks
State:California
“Do not track”, an absolutely fabulous idea! Please make it a reality. My personal preference is a button/setting on my browser. This would be the really the only standardized, cost-effective way to accomplish this goal.

Submission Number: 00023

Received:12/2/2010 6:30:57 AM
Commenter: RobinNelson
State:Oregon
The idea behind the “do not track” option is great, but I am concerned that anything that works against advertising on the internet will result in layered service which greatly favors companies over individuals. Please don’t do anything to change the nature of the internet, which right now is a wonderful tool for everyone, including individual consumers, and one that is largely supported by the advertising that depends on the collecting of these profiles that you are concerned about. I think what you will end up with is far worse than what we have now.

Submission Number: 00024

Received:12/2/2010 6:58:29 AM
Commenter: JohnFechter
State:Minnesota
FTC’s proposal for a “Do Not Track” option is an EXCELLENT idea. I strongly support it because it makes visible the digital trail that is being recorded about online activities. It would allow consumers to decide whether they are OK with having their activities tracked — a common sense and fair notion.

Submission Number: 00025

Received:12/2/2010 7:07:41 AM
Commenter: Fox
State:Pennsylvania
I am very much in favor of the do not track proposals. They should be as strong as possible!!

Submission Number: 00026

Received:12/2/2010 7:08:55 AM
Commenter: MARTINCASEY
Organization:SELF
State:Pennsylvania
I FULLY SUPPORT THIS PROPOSAL TO IMPLEMENT AN INTERNET “DO NOT TRACK OPTION”. TRACKING BY INTERNET COMPANIES IS A SERIOUS EROSION OF PERSONAL PRIVACY AND THE CONSUMER HAS NO PROTECTION AGAINST THE COLLECTION AND STORAGE OF PERSONAL DATA.

AS IT NOW STANDS SEARCH ENGINES COLLECT MORE PRIVATE DATA ABOUT US THAN THE GOVERNMENT.

PLEASE ACT ON CONSUMER’S BEHALF AND PASS THIS BILL.

Submission Number: 00027

Received:12/2/2010 7:49:32 AM
Commenter: Anderson
State:Nebraska
Good idea.

Submission Number: 00028

Received:12/2/2010 9:39:57 AM
Commenter: Smith
State:Florida
I agree with the concept, I am concerned it does not include offline tracking mechanisms that occur without my approval. A company like Catalina Marketing in St. Peterburg Fl parnters with retailers to track my purchases in store and then prints advertisements and coupons to me. I can understand tracking frequent shopper cards, because the consumer has agreed to those terms, but I receive ads based on tracking of my credit card that I regularly use to purchase my groceries, even though I had opted out of recieving marketing materials on my credit card agreement, and I also receive ads based on what I am buying even if I use cash. I would recommend you broaden the ability to opt out, and require retailers to clearly identify the different manners they track your behavior. It may not be legal to use the credit card, or any other financial payment instrument to track and deliver messages, but it occurs on a regular basis.

Submission Number: 00029

Received:12/2/2010 9:48:32 AM
Commenter: CaryJohnson
Organization:First District Attorney’s Office
State:Colorado
This is a great movement in the right direction. I strongly agree with the steps you are taking to protect consumer’s personal habits and trust that you do not back away from this process. Trust that some strong mechanism for enforcement is also included.

Submission Number: 00030

Received:12/2/2010 9:52:16 AM
Commenter: Darlene Tester
State:Minnesota
Why is the FTC making an assumption that people don’t want the information provided by companies? If the FTC’s report is to be accurate in the beliefs and desires of the American public, it should establish some form of polling place to ask the question of the American public — Are the new technologies surrounding focused marketing providing you with information you want to have or is that focused marketing invading your privacy? I believe the FTC may be surprised by the results. I would assume that the majority of people under the age of 40 don’t care and people over the age of 40 believe it’s an invasion of privacy. The FTC should make more of an effort to determine what the American public wants rather than based their report results on what they assume is going on out in cyber space. As a college instructor in forensics and computer law, I find my students accepting of ad tracking — they see it as a fact of life rather than an invasion of privacy (the average age of my students is 26).

Submission Number: 00031

Received:12/2/2010 10:24:00 AM
Commenter: Merriman
State:Washington
Attachments: 00031-56474.pdf Size: 257 KB
Device fingerprinting is apparently being moved to as a replacement for cookies as a means to track consumers. Cookies as persistent identifiers were bad enough. “Do Not Track” should be an option for all consumers regardless of the technology used. I’d even prefer opt in only tracking if it wasn’t burried in the privacy policies as a condition of using a site.

“It’s tough even for sophisticated Web surfers to tell if their gear is being fingerprinted. Even if people modify their machines—adding or deleting fonts, or updating software—fingerprinters often can still recognize them. There’s not yet a way for people to delete fingerprints that have been collected. In short, fingerprinting is largely invisible, tough to fend off and semi-permanent.”

“Blue Cava also is seeking to use a controversial technique of matching online data about people with catalogs of offline information about them, such as property records, motor-vehicle registrations, income estimates and other details. It works like this: An individual logs into a website using a name or e-mail address.

The website shares those details with an offline-data company, which uses the email address or name to look up its files about the person.

The data company then strips out the user’s name and passes BlueCava information from offline databases. BlueCava then adds those personal details to its profile of that device.

As a result, BlueCava expects to have extremely detailed profiles of devices that could be more useful to marketers. In its privacy policy, BlueCava says it plans to hang onto device data “for the foreseeable future.”

This combining of “off-line” data with a device profile is particularly troubling. The next step may be adding surfing habits to credit histories or other databases.

The other problem is there is nowhere that a consumer can even see what these companies have accumulated about them nor a means of correcting the information.

I don’t mind display advertising. Web sites have to make money. I object to this kind of information gathering. Advertisers can do what they have previously done which is advertise on sites that attract likely prospects for their product or service.

Please see attached WSJ report that contains the quoted information.

Submission Number: 00032

Received:12/2/2010 10:31:28 AM
Commenter: BrettSinger
Organization:Citizen
State:California
I fully and completely support a requirement that no commercial business should be allowed to track internet user’s online activities or compile profiles about the users without the users knowledge AND expressly provided approval. To ensure that such a rule is enforced in a meaningful manner, consent forms should be required to be written in simple, understandable language and be brief. The key is to convey the basic scope of the tracking and profiling activity. The commission should show discretion Long, legal forms that cover every detailed aspect hurt rather than help the situation b/c nobody will read them.

Submission Number: 00033

Received:12/2/2010 10:42:28 AM
Commenter: JakeWinter
State:Minnesota
I have great concern over this proposal. I work at a company in which my job is to track and analyze the behaviors of visitors to our website. As a direct result of my research and analysis, I make recommendations to improve the website and make it easier for our customers to use. Through this optimization, we can provide the best user experience possible for our customers.

It is this responsive feedback and optimization that has made the Internet the revolutionary communication tool it is today. The ability to quickly discern an entire population’s frustration and pain points allows the Internet to be the most quickly reactive channel to ever exist. Other channels have to resort to representative samples that slow and restrict growth. That is exactly why the Internet has had the explosive growth and innovation in the past ten years. The tracking you are advocating to suppress is the cause for Internet becoming the burgeoning success it is. By demonizing and creating fear among Internet users, you are killing the exact innovations that spurred its growth. The work we do is not nefarious. It does not deal in personally identifiable information. It keeps everyone anonymous. It is not used in ways that take advantage of people’s data. It is used to make the Internet a better tool for the people that use it. The shortcoming of this proposal is that it looks to evaluate all tracking equally. Yes, there are bad eggs out there that use behavioral tracking data for pursuits that are not ethical. Those should be dealt with on a case-by-case basis. A blanket condemnation of an otherwise beneficial industry would only stifle innovation and growth for the Internet as a whole. Not to mention kill jobs, like mine, in a recovering economy.

The failure of my industry is a lack of voice. We have not spoken loud enough or clear enough about what we track, and how we use it to better the Internet. Without the tracking we provide, Google and Facebook simply would not exist. The experiences that Internet users enjoy every day are enabled by the tracking of everyone’s behavior. If that were undermined, innovation and growth would slow down as companies have to once again use representative samples of populations to optimize their products. This would slow down the ability for these companies to react and result in the Internet no longer being able to be the cutting edge for innovation.

Please take these comments into consideration as you move forward. And please, stop demonizing an industry and practice that has been overlooked and unappreciated since its creation.

Thank you for your time,
Jake Winter

Submission Number: 00034

Received:12/2/2010 11:16:01 AM
Commenter: MargaretHall
State:Arkansas
The proposed “do not track” regulation is yet another example of unnecessary gov’t interference and unnecessary wasteful spending.

This is an opportunity for the private sector. My browser (Firefox) already has a “cookie blocker”…it would be a simple matter for Microsoft to add one to IE…Google to add one to Chrome…Apple to add one to Safari. In fact, they may already have them! My internet security suite also has tracking cookie protection that treats any tracking cookies that get through Firefox’s “cookie safe” like a virus and removes them automatically. So I already have far MORE protection any new “do not track” registry could begin to provide. And what is available to me is available to everyone who uses the internet. Whether to use it does require taking personal responsibility for one’s own safety, just as it’s one’s own responsibility to install AV and firewall software and keep them updated.

So this proposed regulation is not needed! Nor would it work, because so many commercial domains are located outside the US. What would we do if we want to block TRACKING cookies from a retailer or mfr today, but want to search the site 6 months from now? We would not be able to do that because it would be necessary to re-enable cookies–which could NOT be done if that company were on any federal “do not track” list without removing our computer entirely? And what happens when we buy a new computer?

The proposed “do not track” list is just one more example of government “nanny state” interference that would actually allow the government to track the sites we visit by keeping track of who we add to the list.

Bottom line: It’s not needed, it’s insidious, an unnecessary expense, and it won’t work–the worst idea to come along in at least a decade…all of which anyone in the FTC who has even a moderate level of computer literacy should already know without my telling you.

Submission Number: 00035

Received:12/2/2010 11:34:12 AM
Commenter: billbittner
Organization:self
State:New Jersey
Great start, but another aspect to this whole thing is email addresses. People’s email address has become another personal identifier that can be used to link everything they write and everything they do (because many sites use the email as the userid) online.

Just as the FCC finally separated phone numbers from carriers and allowed people to own their number, email addresses must be separated from email providers and not be allowed to be used as userids or links to connect online activity.

Until privacy (ie security) can be assured, cloud computing will be a pipe dream.

Submission Number: 00036

Received:12/2/2010 11:54:55 AM
Commenter: ElizabethHardin
State:Minnesota
I strongly encourage the FTC to implement the “Do Not Track” mechanism, as I am very uncomfortable with my internet activities being shared and gathered and tracked. I value my privacy and I do not feel that it is appropriate that my activities are being monitored and utilized for the financial benefit of a third party.

Submission Number: 00037

Received:12/2/2010 12:01:37 PM
Commenter: KandyRathinasamy
State:Massachusetts
It is clear that consumers need better control over online privacy. An easy-to-use do-not-track mechanism is required and long overdue. Online companies have built layers of brokers that make it EXTREMELY difficult to opt out of tracking of online behavior. Privacy policies (even for for leading web sites) are very hard to understand and often just say that there may be 3rd party cookies etc on a site. The 3rd party’s policies may be hard (if not impossible) to find and opt out of, even if you were willing to take the time and effort to avoid being tracked. Sites can change policies if/when they choose with little if any notification (e.g. Facebook’s much maligned changes to make more of your information more public). Further, it is impossible to find out what data about you is in these databases. Consumers MUST be offered a UNIVERSAL (not site by site, as that just causes the hard-to-peel layers we have today) and easy-to-use opt-out mechanism.

Submission Number: 00038

Received:12/2/2010 12:26:57 PM
Commenter: KathrynRoecklein
Organization:University of Pittsburgh
State:Pennsylvania
I am highly in favor of the FTC’s proposal to balance the privacy rights that I have as a consumer with the needs of businesses that use consumer information to provide certain services. The proposed “Do Not Track” mechanism is appropriate because it would allow me to choose what to share and when, and to know that information about me is not being tracked without my explicit consent.

Submission Number: 00039

Received:12/2/2010 12:43:31 PM
Commenter: Murray
State:Vermont
Thank you VERY MUCH for proposing the “Do Not Track” mechanism! I support this 100%. The situation has increasingly felt out of control in favor of those disrespecting other human beings’ right to privacy by pursuing what have appeared to be greed-driven activities. If you believe that omitting information is the equivalent of lying, tracking people without letting them know you’re doing it is deceitful. Not giving them the option to opt out limits their travels on the web.

On a related note, I’d also request that you consider creating a mechanism that would prohibit someone from uploading pictures or video to the internet without the permission of the person in the video or picture.

Thank you for your help.

Submission Number: 00040

Received:12/2/2010 12:59:21 PM
Commenter: ChrisSundt
State:Outside the United States
I strongly support the concepts behind this proposal. However, I am seriously concerned at the idea that a “Do Not Track” mechanism is enabled by some form of cookie on the user’s browser. As a security consultant I always recommend that people delete all cookies for security reasons when closing their browser. The recent UK BT/Phorm trial used such a mechanism and I found it tedious to have to opt-out every time I loaded my browser. The increasing use of “persistent” cookies – often installed without the knowledge of the user – is causing significant problems and exposing users to unknowing profiling by unscrupulous companies.

A more permanent mechanism needs to be created that is visible to the user – such as an explicit plugin or addon to the browser that the user is asked to install explicitly.

Regards. Chris Sundt

Submission Number: 00041

Received:12/2/2010 1:48:44 PM
Commenter: ChristopherGoyra
State:California
I feel that it is completely necessary for this option. Just as there is a do not call list for people who don’t care to be bothered by telemarketers there should be the same for people who do not want their public and or personal information taken and sold or stored on the internet. I feel that there are those who are concerned over one or both of these matters as well most are oblivious to how much information is actually collected. Google being possibly the number one offender of this as well not being all truthful with their practices such as those with their streeview cars WiFi snooping is absurd and needs to be addressed. Although it would be nice to have it as an option built into web browsers I feel it may be better if this is implemented into the OS based on the users MAC Address of their network cards. This unique address would be something along the lines of a phone number, unique and the main difference is you cannot change your MAC Address like an IP Address. I believe respect comes first especially to ones privacy just as our nations. As an example when I am not at work I help amongst friends protecting their machines as well as their privacy with ad blockers and tracking server blockers. Having to go that extent is nearly the same as having to install anti-virus that is sufficient to protect users which I feel is absurd as virus’s are used for malicious purposes by users to fool users in spending money or setting machines up for ad clicking to produce false revenue. In this instance companies are using tracking cookies and other methods to take users information and sell it off to others which I feel is similar in comparison yet this is being operated by big businesses such as Google making 97% of their revenue off such. I feel all businesses should be fair and generate revenue off talent and innovation not taking peoples information and selling it. The reason for a system wide block by MAC address is that web browsers are not the only ones to harvest and transfer information. There are a lot of software applications that use this tactic as well mainly Google with all their applications by default set to collect and usually make it difficult to find how to turn it of and that is even if the user is aware this is happening. I feel this is a huge security threat to everyone using the internet which these days is just about everyone. Please take my statement into consideration for this matter. Thanks.

Submission Number: 00042

Received:12/2/2010 2:11:33 PM
Commenter: LonDiffenderfer
State:Pennsylvania
A “Do Not Track” mechanism, allowing consumers to choose whether to allow the collection of data regarding their online searching and browsing activities, is long overdue. It should be implemented now. Consumers should not be required to sift through legalese trying to determine whether or not a company is going to be tracking their online activities.

Submission Number: 00043

Received:12/2/2010 2:25:08 PM
Commenter: M.Dahlquist
State:California
Just wanted to say I am so thankful for the Commission’s proposal of this policy. I am shocked each day by the abuses of privacy on the web. Thank you thank you thank you.

Submission Number: 00044

Received:12/2/2010 2:46:13 PM
Commenter: Greenwald
State:New York
I would imagine that because Do Not Track List lacks the ability to immediately alert consumers when the list is violated the same way the Do Not Call List does, enforcment would have serious difficulty.

The reason the industry has adopted the “opt-out” standard is because consumers have demonstrated a material desire not to exchange personal information for most of the free content on the web. This opaque and usually clandestine “market place” is very inefficient in compensating conumers for the personal information, which clearly has economic value. The only way to truly empower consumers is to require an “opt-in” standard. Then consumers will be faced with a clear and simple choice of whether they want to exchange their information for content. This is unlikely to destroy the economics of the web, but rather make it a more open and trustworthy marketplace. Some consumers, myself included, would often rather pay for content rather than surrender control over identity. Many others would probably not. But at least a clear choice would be provided.

It is telling that in the recent Wall Street Journal series “What They Know”, the company that is trying to identify devices boasts something akin to an 85% tracking success rate as opposed to the 70something% rate of cookie tracking. What this indicates is a concerted effort by a sizable number of people to go to great inconvienances to try and not be tracked. A simple Opt-In to tracking similar to what Mozilla developers came up with before being pressured to scrap the idea would be a more effective solution that would empower consumers rather than a faith based Do Not Track feature.

Any attempt to stop this type of behavior by marketers would have to be complemented by regulation (preferably law) which would not allow marketers to circumvent the spirit of the law and seek ever more devious means to acquire data.

All prior forms of media have had success selling advertising based on statistically representative demographic information about users. It is understandable why marketers and advertisers would want as much person specific information as possible, but it is not necessary and completely ignores the desires of at least a material number of consumers. Openness and transparency, the features often trumpeted by internet evangelicals is hypocritically absent in marketing practices, only because consumers have demonstrated a desire to push back.

Finally, it is telling that Eric Schmidt, Google CEO, has admitted to having six different personal computers because of security concerns. What are the rest of us who can not afford such extravegance to do? Don’t use the internet if yopu don’t want people to know what you are doing is Mr. Schmidt’s response. This in a nutshell sums up the current state of affairs in the internet ecosystem.

Submission Number: 00045

Received:12/2/2010 2:50:13 PM
Commenter: ginagonzales
State:Texas
The FTC needs to protect us from unscrupulous businesses and people.
I am all for a sign up list to protect my privacy. Please help us.

Submission Number: 00046

Received:12/2/2010 3:40:47 PM
Commenter: Greenwald
State:New York
Having just read the testimony by Joseph Pasqua, VP of Research at Symantec, I would like to add what I consider to be an important point. I am in complete agreement with Mr. Pacqua’s premise that “Online privacy is not possible without online security.”

However, Mr. Pasqua seems concerned that a Do Not Track list may undermine internet security. It may be in conflict with certain online security practices, but it is important to not what Peiter Zatko, currently working for DARPA and formerly head of technology at Mr. Pasqua’s company Symantec was quoted in the original edition of a Febuary 10th, 2010 CNet article that (and I am paraphrasing but I recommend asking Mr. Zatko directly) that the problem with working at Symantec was that there is an inherent conflict of interest. On the opne hand you have to produce an effective defense against security attacks, but on the other hand, you don’t want to be overly effective for fear of putting yourself out of business. Now that he is at DARPA he says he is looking forward to trying to solve the challenge in an intellectually honest way. Thus there should be serious questioning as to the efficacy of the security methods Mr. Pasqua is afraid a Do Not Track approach would potentially limit. For instance, instead of tracking everyone’s browsing and online activity with the hope of ferreting out fraud, perhaps a simpler and more effective measure would be to give users something akin to the “semi-random” number generating fobs online brokers give to their clients.

Submission Number: 00047

Received:12/2/2010 5:08:55 PM
Commenter: Cramer
State:Michigan
I fully support restricting anyone, any company, any orginization or goverment agency from tracking, recording, preserving, logging, or retaining any personal internet searches, browsing, or web site visits without full & frequent disclosure to the user.

Submission Number: 00048

Received:12/2/2010 5:14:01 PM
Commenter: CherryKillingsworth
State:Kansas
Please approve this legislation. I constantly get e-mails from people whao want to sell me Penis enlargement supplements and want me to look at their naked pictures. It is awful that I have to receive these messages and I wonder if my 16 year old son has recieved them also. Please, pass this legislation.

Submission Number: 00049

Received:12/2/2010 5:19:33 PM
Commenter: BradleyBachman
State:Pennsylvania
Agree completely with the idea of having the “do not track” button on the web browser. Hope to see it soon. Thanks for taking the stance you have on this issue.
Brad

Submission Number: 00050

Received:12/2/2010 5:19:57 PM
Commenter: Kuriger
State:Pennsylvania
It is my right not to be tracked via the internet.

Submission Number: 00051

Received:12/2/2010 5:27:59 PM
Commenter: LarryMoyer
Organization:none
State:Pennsylvania
I saw a news report on tv and I am all for something to be done for regulating what online website companies track and information they obtain and store. As well as some regulations on buying/selling emails addresses to other companies/websites that a person never visited him or herself. Something to help stop spam emails would be nice as well.

Submission Number: 00052

Received:12/2/2010 5:28:00 PM
Commenter: SheilaHolt
State:Pennsylvania
Please institute an opt-in national do-not-track internet requirement, such as the national do-not-call list.

Thank you for helping to protect my privacy.

Submission Number: 00053

Received:12/2/2010 5:29:00 PM
Commenter: ChristineShuble
State:Pennsylvania
Please, do consider approving an “opt out” opportunity to remove people from advertising sites. This is a useless opportunity for the offender to collect information that I would rather they do not
have access to. Not only does it take up time, but look at the endless traffic it creates on an already too busy internet. Do your part in improving the Internet, instead of adding to the problems that already exist. Thank You.
Christine M. Shuble

Submission Number: 00054

Received:12/2/2010 5:32:01 PM
Commenter: JeffreyHilty
State:Pennsylvania
I agree with the FTC’s proposal to create a one-stop location for a do not track option in an internet browser window. I think this creates a user-friendly approach to not be tracked on-line much in the same way as the current do-not-call approach for phone service. Thank-you for doing this for the public.

Submission Number: 00055

Received:12/2/2010 5:37:26 PM
Commenter: ChrisParsons
State:Oregon
I completely favor implementing A NO TRACK mechanism.

Submission Number: 00056

Received:12/2/2010 5:38:11 PM
Commenter: gregcover
State:California
I support a NO TRACK list

Submission Number: 00057

Received:12/2/2010 5:40:36 PM
Commenter: A.Neubauer
State:Pennsylvania
I don’t think we should be kept track on for doing anything unless it’s part of a lawful investigation. Otherwise, no to tracking…

Submission Number: 00058

Received:12/2/2010 5:40:37 PM
Commenter: JohnRusso
State:Pennsylvania
I strong appove of no tracking

Submission Number: 00059

Received:12/2/2010 5:43:13 PM
Commenter: C. AlexanderCohen
State:New Hampshire
I believe this is a fine idea and commend those commissioners who propose and back it. It is going on past time for some action like this to happen.

If it were true that the market can and would protect consumers, after some 15 years of widespread internet use, it would have already happened. Instead, corporations, etc. have shown that, when the incentive to use others data for profit exists, they will take advantage of it. Technology, as you note, is becoming more and more intrusive, and the threat thus greater.

It should be an obvious matter of fact that, at base, consumers personal information (if it is property) belongs to the consumer. Informed consent should thus be given before signing away those rights.

As I say, if our government is truly “of the people, by the people and for the people” and not “of the people by the corporations, for the corporations” this action is past due.

(NB: Personhood of corporations is a separate kettle of fish, that need not be addressed here, but suffice it to say, I have historical evidence that it is, in fact, a crock…)

Submission Number: 00062

Received:12/2/2010 5:49:04 PM
Commenter: SusanBolinski
State:Pennsylvania
respect my privacy

Submission Number: 00063

Received:12/2/2010 5:50:44 PM
Commenter: GregoryPerry
State:Arizona
I strongly feel that anyone tracking me on line especially for the purpose of solicitation, harassment,voyeurism,etc. without express permission is an unacceptable invasion of all of our privacy. Even law enforcement agencies need probable cause before doing such. If I am able to learn who is doing this to me and for what purpose, if I am violated I should have the option seek action aganist that person or company. I should at least have the right to know who is tracking me while on line and for what purpose.

Submission Number: 00064

Received:12/2/2010 5:51:19 PM
Commenter: MMooney
Organization:none
State:New York
I strongly support the creation of a a “Do Not Track” mechanism, to be available to all consumers. Granted, there may be a benefit to consumers, who may be informed of new products and services, based on information gathered by tracking. However, consumers should be given the choice of being tracked, even for this or other good purposes. Online searching and browsing conducted in one’s home, on one’s own computer–should not be monitored any more than one’s snailmail or phone calls should be monitored without one’s express permission, or for some compelling and legally permitted reason. I hope that the FTC succeeds in the daunting task of addressing the dangers posed by the ever-evolving Internet technology. Such can be used for good, but consumers should be given the right to make that determination for themselves, as regards their own browsing and searching activities.

Submission Number: 00065

Received:12/2/2010 5:52:24 PM
Commenter: DReis
Organization:United Health Group and Walgreens
State:Connecticut
This addition would be a massive aide in protecting everyone’s privacy, however if the “Do Not Track” list is indeed implimented, then certain precautions would have to be taken in order to prevent it’s abuse. One important question I have, and im sure many other concernced Americans have is: Would security departments (think police, DEA, etc) be able to monitor the activities of people who are potentially commiting crimes even if these people are under the veil of the “Do Not Track” feature?

This tool certainly needs to have the functionality to track (and ideally, report) people who are participating in illegal, and/or dangerous activities!

If the “Do Not Track” tool can be implemented with the aforementioned feature, then I think it would be a wonderful addition to our lives!

Submission Number: 00066

Received:12/2/2010 5:56:53 PM
Commenter: StevenDaniel
State:Illinois
I support the “do not track” proposal. I don’t like performance reducing software on my computers being installed without my approval.

thanks and regards,
Steven Daniel

Submission Number: 00067

Received:12/2/2010 5:58:18 PM
Commenter: VINCENT DPIRAINO
Organization:N/A
State:Pennsylvania
I agree with ‘Do Not Track’ and ask also, for a ‘No Junk Mail’ list, so they quit sending unsolicited ads!
AND, when I ‘UNsubscribe’ from any site, I want it done that day, NOT 7-10 days later, it should be automatic when I send my email addy to unsubscribe, I don’t want to hear from them again, period!

Submission Number: 00068

Received:12/2/2010 5:58:39 PM
Commenter: CrystalinElmore
State:Kentucky
I would like to know would this do not track list work?

Submission Number: 00069

Received:12/2/2010 6:00:52 PM
Commenter: colleenmcginn
State:California
I am for the protection of consumers right to privacy. Please allow consumers to “OPT OUT” of internet tracking. It’s an invasion of privacy. Thank youl

Submission Number: 00071

Received:12/2/2010 6:14:10 PM
Commenter: ThomasSpudic
State:Pennsylvania
I am tired of opening my e-mail and sometimes finding 8 to 10 spam messages regarding people or things in which I have no interest. If there was a way to sign a list to eliminate unwanted spam, I would definitely be interested in signing up.

Submission Number: 00072

Received:12/2/2010 6:14:54 PM
Commenter: CaroleHolsing
State:Pennsylvania
I am absolutely in favor of an internet “Do Not Track” law.Thanks.

Submission Number: 00073

Received:12/2/2010 6:29:20 PM
Commenter: gthompson
State:Illinois
Please pass Do Not Track. There are enough ads shoved in our faces everyday (billboards, ballparks, stores, etc.) as it is. Please don’t let the ad companies run the internet.

Submission Number: 00074

Received:12/2/2010 6:31:38 PM
Commenter: JohnFarrington
State:North Carolina
Please do your best to make the Do Not Track List a reality. Anything that can be done to insure privacy is welcome.

Submission Number: 00075

Received:12/2/2010 6:32:37 PM
Commenter: Pecora
State:Rhode Island
I fully agree with a ‘Do Not Track’ law. I am tired of being targeted for myriad advertisements. This is an invasion of my privacy. I would like to enjoy the freedom of accessing the internet without the fear of someone stealing my identity, or all the other ills that this condones. Please help us preserve our fundamental freedoms.

Submission Number: 00076

Received:12/2/2010 6:43:59 PM
Commenter: Guthrie
State:Ohio
I think it would be a great idea to have a “Do not track list” for internet browsing. Afterall, we don’t have anyone tracking us while we shop from store to store. I would also like to see something done about a unwanted mailings list. I still receive mail from advertising companies for my grandparents who have been dead for years!! Both of my grandmothers died six years ago and my paternal grandfather died SIXTEEN YEARS AGO !! and after repeated calls to these companies they still send the mailings!! Please Help! Thank You.

Submission Number: 00077

Received:12/2/2010 6:45:07 PM
Commenter: RYarb
State:Florida
Please, please enact this privacy rule. The “Do Not Call” list worked wonderfully. There’s no reason this shouldn’t also.Waiting will only allow the advertisers to find a way to cicumvent the rule. The FTC has needed to be more proactive with electronic communication issues since the internet began. Unfortunately, always late and trying to “catch up” to fix problems after they are so well established that the ones who benefit most,(scammers,spammers,crooks and even honest ones),have lobbyists to block implementation or water down the rules to make them essentially useless. Again, please help protect consumer privacy (a right we all possess) by passing rules to control this vast marketplace.

Submission Number: 00078

Received:12/2/2010 6:46:37 PM
Commenter: CarlyJerome
State:Colorado
I don’t like that websites can ‘track’ me and see what I’m doing and where I have been. It’s a complete violation of my privacy. If websites would like to continue to do this, I feel that they should have to have a disclaimer before entering the site.

Submission Number: 00080

Received:12/2/2010 6:51:44 PM
Commenter: JoyKeegans
State:Florida
I believe it should be illegal for companies to track one’s searches on the Internet. It has been abundantly apparent to me for years now that this happens. Each time, as the result of shopping or perhaps, just browsing, or even seeking information, I receive a litany of unsolicited e-mails from unknown throughout the world, wanting to sell something similar to what I may have researched. I am insulted by the barrage that never ends. Furthermore, it is so very obvious that e-mails are being read, because I usually receive several e-mails from unknown posing with names lifted from my e-mails, with the intention to tricking me into thinking it may be a friend’s e-mail. This is so wrong. And, the Security Tool virus has caused two new computer purchases in less than one year, because it never really ‘leaves’ your computer once it comes into it… Please, aren’t we passed the pioneer stage and ready to set stricter parameters with this new wave of technology? Thank you, Federal Trade Commission, for all you do!

Submission Number: 00081

Received:12/2/2010 6:56:21 PM
Commenter: MichaelGeary
State:Pennsylvania
I favor the “DO NOT TRACK” REGULATION

Submission Number: 00083

Received:12/2/2010 7:20:53 PM
Commenter: McDaniel
State:Pennsylvania
I support the FTC initiative to create a “Do Not Track” list for Internet users. This is an idea long overdue. Too long, companies and even individuals, have been building expansive databases with dossiers on users. This info can be sold to others just like a mailing list. This could prove problematic in the hands of a disreputable person or firm that acquires the information. No one needs to be continuously spammed with unsolicited messages, or worse, due to persons snooping through their life or business without permission via information gathered.

This initiative is a way for the FTC to finally force these persons or companies to cease tracking people. Wiretapping is illegal on phone lines. Essentially, this tracking of Internet usage is similar. It needs to be abolished as well, except possibly for law enforcement,with a duly obtained warrant, when tracking sexual predators, or terrorists.

I also, believe that if you wish to continue to see commerce and trade flourish via the Internet, bold moves like this are needed to bring order and security to the “Digital “. Citizens and companies alike should feel confident in using the resource, rather than feeling like you are walking down a dark alley in a bad neighborhood at midnight.

Submission Number: 00084

Received:12/2/2010 7:22:40 PM
Commenter: Hess
State:Colorado
If someone was stalking me and watching everything I did in my daily life and I found out, I would be able to get a restraining order to stop them. So now I’m on the internet and someone is stalking me and watching everything I do and I have no recourse to stop them? Something is very wrong. What happened to the government protecting our privacy? There is no good argument from these invaders of privacy that can validate what they do!

Submission Number: 00085

Received:12/2/2010 7:39:21 PM
Commenter: RobertOwens
State:Georgia
I think it is a shame that we need to pass one more law to insure my privacy of thought and opinions. It amazes me that you have to pay or pass laws to “not” do anything. Please I should not have to share what I am thinking or wondering about to not be tracked by companies on the internet. National securety can always supina to get the info.

Submission Number: 00086

Received:12/2/2010 7:39:46 PM
Commenter: DebbieHall
Organization:self
State:Illinois
Please save us from the ongoing intrusion of our privacy by online tracking. We are so overwhelmed and bombarded by an internet society that has no regard for the peace of mind we deserve. While this was not an option when my children were young it seems it would help parents keep their children a little safer. Thank you for your time and consideration.

Debbie

Submission Number: 00087

Received:12/2/2010 7:43:22 PM
Commenter: DwaylaLukas
State:Pennsylvania
I would love to see a national “Do Not Track” code in effect.

Thank you.

Submission Number: 00088

Received:12/2/2010 7:53:36 PM
Commenter: PamelaPtacek
State:Michigan
I would welcome the Do Not Track list. Whenever I buy contacts online, I suddenly start getting (unwelcome) emails and advertisements from other contact suppliers. Same thing when I search for information–suddenly all the ads on my page seem to be relevant to my recent search. It’s creepy.

Submission Number: 00089

Received:12/2/2010 7:58:28 PM
Commenter: RichardMogavero
State:Pennsylvania
I have been on the internet and bulletin boards before the internet and I am strongly against any type of tracing or tracking by anyone or anything like persons, corporations, bots etc.

Richard F. Mogavero

Submission Number: 00090

Received:12/2/2010 8:07:20 PM
Commenter: SalvatoreAversa
State:Pennsylvania
You must protect our privacy in every new technology as needed. Too much of our information is tracked, and it is infringing on our rights. Please approve the Do Not Track list. Thank You

Submission Number: 00091

Received:12/2/2010 8:08:11 PM
Commenter: jodicole
State:Texas
this is a wonderful idea!!!! Longtime needed. the online “tracking” has been out of line for a long time

Submission Number: 00092

Received:12/2/2010 8:38:08 PM
Commenter: GeorgeKosana
Organization:Image Ten Productions
State:Pennsylvania
I had to buy a new computer, change my server, and e-mail address because I had more than 914 contaminants such as worms, phishing, viruses, and trojan horses. I lost my custom built computer with 2 terrabytes of memory that cost me more than 3,000.00 dollars to have it built, plus what it cost me to replace it. All because I was deluged by unsolicited e-mails. One originated from my agent. There was no reason to doubt its origin. When I replied; I was told a hacker got into my agents address book and contaminated everyone.
I don’t want anyone tracking me or contacting me unless I seek them out. I think those who invade my privacy should be arrested.

Submission Number: 00093

Received:12/2/2010 8:44:53 PM
Commenter: MicahPowell
State:Utah
I think this is a great idea, infact I think it is invasion of privacy. Please pass this, it only makes sense!

Submission Number: 00094

Received:12/2/2010 9:33:49 PM
Commenter: RoyBreed
State:Michigan
I certainly feel it’s an invasion of privacy to track my places on Computer,and it certainly is not consistent with Government Policies..

Submission Number: 00095

Received:12/2/2010 9:34:58 PM
Commenter: EllenKlinefelter
State:Kansas
PLEASE get this Do-Not-Track legislation PASSED. And SOON!!!!!!!

Submission Number: 00096

Received:12/2/2010 9:35:47 PM
Commenter: RoyThompson
State:Texas
Please move forward with the “DO NOT Track” list.

please protect our privacy.

thanks you

Roy

Submission Number: 00097

Received:12/2/2010 10:05:14 PM
Commenter: BarryAaron
State:Pennsylvania
I would like to have a do not track list. I am part of the do call list.

Barry

Submission Number: 00098

Received:12/2/2010 10:33:59 PM
Commenter: MarshaMiddleton
Organization:N/A
State:Texas
Please enact,implement and ENFORCE a “Do Not Track” policy for consumer’s internet browsers. We are absolutely barraged with adds and other notes that we did not solicit or want and it is almost unmanageable. We need some kind of relief. Please, Please, Please help by protecting our privacy which is compromised enough already in this day and age. Thank you very much for allowing me to have input into this process.

Submission Number: 00099

Received:12/2/2010 10:57:11 PM
Commenter: FrankMaio
State:Florida
I stongly feel that we as Americans deserve the right to have some privacy.

Submission Number: 00100

Received:12/2/2010 10:58:59 PM
Commenter: dyoung
State:Arizona
I do request explicit confidential treatment I do not want my name to be a matter of public record.I know for a fact that I’m tracked online because every time I search something I get emails about the subject I have searched it is the same as ease dropping or line tapping or back in the day a telephone party line, being taped without having knowledge of it.I think it should be illegal to track anyone,unless they are suspected of searching for child porn, or terrorist actions or unlawful acts.

Submission Number: 00101

Received:12/2/2010 11:25:01 PM
Commenter: MatthewKristoff
State:Georgia
This is super! Just keep in mind the punishment should be somewhat “stiff” because you know some are going to do it anyway. Make it illegal to sell emails without consent (not hidden in some small print) too!

Submission Number: 00103

Received:12/3/2010 2:01:12 AM
Commenter: murraykatz
State:Illinois
A do not track law is absoltely necessary. Any tracking is an invasion of privacy and personal information should not be bought and sold by third parties.

Submission Number: 00104

Received:12/3/2010 2:51:12 AM
Commenter: tommypope
State:Texas
tracking is an invasion of privacy……..

Submission Number: 00105

Received:12/3/2010 2:51:28 AM
Commenter: shaner
State:Pennsylvania
P;ease pass this bill, it is a shame we can not research sites and feel comfortable about it. There are too many hackers out there to use this against you. Thank You

Submission Number: 00106

Received:12/3/2010 2:53:22 AM
Commenter: FrancisRach
State:Pennsylvania
I am in favor of initiating a do not track list and that it be all inclusive so that no business, charity, non-profit be able to access your IP address.
Thank You

Submission Number: 00107

Received:12/3/2010 3:12:07 AM
Commenter: ElaineHazel
State:Pennsylvania
I think it is a good idea to be able to stop people from tracking what I do on the computer.

Submission Number: 00108

Received:12/3/2010 4:06:04 AM
Commenter: MistyReed
State:California
I think that this should be passed! Why is it anyone elses business where we go online. I have to go in daily and clean out 30 tracking cookies for visiting a few websites that I visit regularly. I think it’s an invasion of privacy and the reason why viruses stay in our PC’s so long. Thank you, Misty

Submission Number: 00109

Received:12/3/2010 5:32:02 AM
Commenter: WilliamMartin
State:Texas
They get so much free, tax breaks, discount postage. I am sick of giving them a free ride. They should be excluded or pay the indiviodual.

Submission Number: 00110

Received:12/3/2010 6:25:46 AM
Commenter: BenjaminWilliams
State:Pennsylvania
Please pass a do not track bill and put some teeth into it

Submission Number: 00111

Received:12/3/2010 7:37:42 AM
Commenter: LawrenceYokopenic
State:Pennsylvania
To whom it may concern;
In the last 8 years we have lost so much of our privacy that I feel like a character in the novel 1984. Would you please institute the “do not track” for the internet. Thank you.

Submission Number: 00112

Received:12/3/2010 7:57:10 AM
Commenter: JohnHeitz
Organization:Retired
State:New York
My comment is in the form of a question. Will consumers be able to choose whether to allow the collection of data regarding their online searching and browsing activities by being able to manually enable or disable the “Do Not Track” mechanism?. [ ]Yes [ ]No If appropriate, please put an X in one of the above blocks and reply to Thank you.

Submission Number: 00113

Received:12/3/2010 8:57:00 AM
Commenter: KimberlyCostello
State:Illinois
DO NOT TRACK list HAS to happen! Not only is it annoying, it is clearly proven to be unsafe for way too many consumers! The thief on the other side of the phone is not recogonizable by way too many innocent people that get sucked into their scams! How many seniors would have been spared the loss of their already limited income if the Do Not Track was already in place!

This is truly a no brainer! How about moving on to companies selling your info to anyone they please. How about NOT letting financial institutes “Pre-Approve” anyone, whether they are run your credit or not. Help us to keep our privacy private! Kim Costello

Submission Number: 00114

Received:12/3/2010 9:32:04 AM
Commenter: harlor
State:Ohio
i love the idea of a do not track for the internet, I have to run my anti spyware daily and am amazed at how many cookies and other things seem to want to big brother me, not cool please help us!

Submission Number: 00115

Received:12/3/2010 9:47:57 AM
Commenter: ChristieNewcamp
State:Pennsylvania
No one should be able to track my movements as a consenting adult without my consent. I understand that a minor may reequire some parental tracking and i support a parents right to monitor minors.

Submission Number: 00116

Received:12/3/2010 10:07:33 AM
Commenter: RobertMiecznikowski
Organization:self
State:Pennsylvania
Please consider creating a no tracking list for all personal computers.Tracking my sites in my opinion is an invasion of privacy.It also creates a variety of pop ups and internet advertisements which I find annoying. Thank you for your consideration.

Submission Number: 00117

Received:12/3/2010 10:12:14 AM
Commenter: joyceramos
State:Connecticut
the “do not track” law would be the best thing since the “do not call list” was started…I hope it passes…. Thank You

Submission Number: 00118

Received:12/3/2010 11:04:21 AM
Commenter: MichaelWilliams
State:California
Yes, I think that this would be a good idea to have a browser option and or options in other applications as well that let one opt out of allowing ones browsing activities tracked and collected. The internet is becoming an ever larger source of threat to each persons identity and privacy.

Though there are technical issues that would have to be overcome. I have no specific expertise in the coding for this. But “opting out” should be instituted to allow functionality and selectivity. “Opting out” should still allow one to otherwise interact on web sites and with businesses of ones choice. Currently many web sites or web fuctionality will not work with out allowing cookies. Many browsers currently allow settings that include blocking of cookies, but then you basically can only view a site but can not make purchases, send forms like this one, or do on line banking, etc. with out cookies being “turned on”. That is an issue that needs to be looked into as well. Therefore opting out of data tracking must be set up to still allow wanted interaction between consumers and web sites. Also it should be selective so the consumer can choose to allow some data tracking to occur with sites one wants to share information with. For example I do not mind getting purchasing suggestions from Amazon due to my previous purchases as some times they suggest CDs, DVDs, and books that I do find interesting that I otherwise would not know about. I prefer these seggestions being shown while viewing Amazon and not from being sent emails. Aslo the “default” selection for all websites should be not to share information with other businesses or associates. Currently unless you are very careful you find your email address spread everywhere.

Submission Number: 00119

Received:12/3/2010 11:17:37 AM
Commenter: GeneKimball
Organization:Retired
State:California
Tagging a web surfer with a cookie makes no sense and we ought to be able to ‘opt in’ rather than ‘opt out’. This was a gimmick started decades ago and should never have been allowed to be put in place without a customer’s approval. This is akin to putting a radio transponder on every citizen who shops the Internet so that the owner of the transponder can track your every move – in the name of commerce. It is an old argument and holds no ground. This is a privacy issue and tracking should not be allowed on a person even in virtual reality. It is time to stop this nonsense and create the list. It has been reported that it would cause a major problem with vendors on the Internet. It would not. They simply need to stop this personal invasion practice.

Submission Number: 00121

Received:12/3/2010 11:27:21 AM
Commenter: KathleenRobinson
State:Pennsylvania
It is imperative that we are able to be assured our personal information remains confidential and not fear identity theft going forward.

Submission Number: 00122

Received:12/3/2010 12:32:06 PM
Commenter: DeborahGerulis
State:Pennsylvania
I definitely am in favor of a do not track regulation.

Submission Number: 00123

Received:12/3/2010 12:48:36 PM
Commenter: klingensmith
State:Pennsylvania
I think any shopping we do online should be confidental and the only way other companies should get it is if it is given to them. there needs to be a “do not track” option for the internet. lets face it our lives are based “online” and we need to protect it.

Submission Number: 00124

Received:12/3/2010 1:40:20 PM
Commenter: Myers
State:Arizona
”Tracking” or “finger printing” should be prohibited unless explicitedly authorized. An “opt-out” feature should be available at anytime! Personal information, whether it’s information about your computer’s “fingerprint” or otherwise, is private. Any attempt to gather personal information without explicit authorization should be illegal! You can’t wiretape without a warrant which requires some modicom of proof of a an illegal act. Your mail can’t be opened and searched. That’s illegal. You can’t break into someone’s home without committing a crime. Census worker can’t take your personal information without your permission. A survey taker can’t ask you about your buying habits without asking you for it and you volunterially giving to him. How did we get to the point where a “cookie,” “malware,” “spyware,” and “finger printing” became acceptable and “legal”? It is unconscionable! Perhaps we should look back to see how telephone companies started publishing names, telephone numbers, and addresses then selling that information. When people signed up for a telephone number did they give the telephone companies permission to sell their information? Not. I use Microsoft’s Internet Explore 8.0 browser and the “In-Private” browsing and filtering. I read the WSJ “What They Know” article featuring Microsoft’s internal debate about “tracking” and how to handle it in IE 8.0. Very interesting stuff. The article makes it clear that software manufacturers and internet website providers have big stakes in “tracking.” Don’t expect them to do anything that jeopardizes sales. Doing the “right thing” for consumer privacy seems beyond them. User Agreements are extortion: pay up with your personal, private information (and money too, in some cases) or you can’t use their product or service. That’s wrong! I “pay” for TV viewing by watching advertisements but I don’t have give up my personal information too. Nielson pays viewers for information about their viewing habits. Why don’t software companies and website providers??? Obviously, my personal information has great value to advertisers. If I want to sell it, pay me for it! Otherwise, ask me to pay for the service that I want to use such as Google, MSN, YouTube, FaceBook, etc. If such services can’t survive then they aren’t providing a service that people value. My personal opinion, if most charged for their services, they would disappear quickly. Where are ethics? Isn’t it wrong to steal? And, make money at it too? Why should they make a profit off information that cost them nothing to obtain? I wish I had that kind of business!!! Okay, I think you get my points and my feeling about this “hot topic.” I can understand advertisers desires for this information but they should not be allowed to have it unless I explicitedly authorize it. Thanks for listening. Myers

Submission Number: 00125

Received:12/3/2010 1:47:56 PM
Commenter: TerryBell
State:Texas
I hate the fact that BIG BROTHER is constantly tracking and then selling, trading or somehow divulging my personal info. And, once you’re on the internet (whether with or without your consent or knowledge), it’s impossible to remove yourself. I am on the “Do Not Call” list, I’ve requested vendors and such to remove me and never contact me. I’ve also filled out their forms which say may be 24 hours or more before you’re removed. But, in the interim, they’re sending out your data! Then, there’s the sneaky ones who have a small checkbox with fine print that says if you “DON’T” want them to share your info, check the box. Well, many of us do not read the fine print and then we start getting bombarded with phone calls at all hours and junk mail. I keep a log here at work of all the calls I’ve asked to be removed from, and yet they still call. Many of these telemarketers have call centers and each one has their own calling list. So, if they have 500 call centers, you’d have to contact each one to be removed. Oh, and then there’s the DO NOT CALL LIST itself which is administered by AT&T. THAT’S THE PROVERBIAL LETTING THE FOX INTO THE HEN HOUSE!!! THIS INVASION OF PRIVACY NEEDS TO STOP! MY BIZ IS MY BIZ AND UNLESS ONE BREAKS THE LAW, NO ONE IS ENTITLED TO MY INFO UNLESS I ALLOW IT. As far as I recall, we’re still the United States of American and have rights.

Submission Number: 00127

Received:12/3/2010 2:04:34 PM
Commenter: AnthonyWaters
State:South Carolina
I think that a “do not track” capability is long overdue and will welcome it with open arms if instituted. Thank you.

Submission Number: 00128

Received:12/3/2010 2:13:41 PM
Commenter: SallyBridges
State:Utah
To the FTC, Privacy is not just for people who are doing sneaky things and do not want to be caught. It is for all of us under the Constitution. The tracking that agencies and businesses do on the internet has spiraled out of control. This is why the “Do not track” proposal is quite overdue. I have nothing to hide from the government, but I do resent the fact that businesses and government entities are acting more and more like stalkers. I don’t like the idea that I have to look over my shoulder, feeling as if I am being followed wherever I go, and tracked in every aspect of my life. It is like I must constantly be on the alert for “Peeping Toms” at my window, just waiting to take advantage of me. This makes me afraid to conduct personal business, or make purchases on the internet. More and more, I see that I am in some vast consumer database that knows more about me than I know about myself. More and more, we are losing our liberties and our rights under the Constitution of the United States of America. The FTC should be in the business of protecting the citizen consumer. This “1984” tracking and spying only helps the corporate world to enslave the average consumer by deviously separating him or her from his or her money. It is time to reign-in these peepers and give everyone a choice as to whether or not the individual wants to allow their lives to be tracked by those who only wish to exploit them for profit, or other devious (or benign) reasons. I urge you to climb out of the bed of the corporate world and allow the consumer to breath free, knowing that she or he is free to use the benefits of cyberspace without being stalked or spied upon on a daily basis. Therefore, I urge you to put a tight reign on commercial internet stalkers by putting up roadblocks to protect the internet user and consumer. Thank you, Sally A. Bridges

Submission Number: 00129

Received:12/3/2010 3:55:34 PM
Commenter: JamesJohnston
State:Missouri
Attachments: 00129-56493.pdf Size: 15 KB
Please see attached document.

Submission Number: 00130

Received:12/3/2010 4:56:03 PM
Commenter: DBOWER
State:Virginia
AS A US CITIZAN WHO USES THE INTERNET DAILY, I FULLY SUPPORT AND DEMAND TOTAL PRIVACY OF MY PERSONAL INFORMATION WHEN USING THE WEB. I ALSO FEEL THAT IT SHOULD BE A REQUIRED DISCLOSE OF BUSINESSES TO NOTIFY ME OF THIER TRACKING BEFORE A SUBMIT BUTTON IS ENTERED, OR ALLOW ME TO OPT OUT OF THIER ACCESS BEFORE HAND. THIS BILL IS CRITICALLY NEEDED. I HAVE USED THE DO NOT CALL LIST, AND WOULD USE THIS LIST.

Submission Number: 00131

Received:12/3/2010 5:25:45 PM
Commenter: Swider
State:New York
I favor the implementation of a “Do Not Track” mechanism.

Submission Number: 00132

Received:12/3/2010 6:24:36 PM
Commenter: Pickella
State:Pennsylvania
I strongly support “Do Not Track.”

Submission Number: 00133

Received:12/3/2010 6:36:58 PM
Commenter: Hinds
State:Pennsylvania
I AGREE WITH THE DO NOT TRACK PROPOSITION. PLEASE PUT THIS INTO LAW.

Submission Number: 00135

Received:12/5/2010 10:51:04 AM
Commenter: AnthonyPickert
Organization:ETS
State:Kansas
Privacy concerns go beyond legitimate company ads. There are individuals and foreign crime groups that target individuals in this country.

1. Each time the computer turns on, Microsoft, Apple, or the local cable company may be able to know
what time you get up each day or what time you are home and may be predicable. Can this info be sold?
2. Political activists, TV & government persons may be targeted for various reasons,
as well as former spouses & neighbors.
3. Aggregated information may be kept in other countries and (like a Swiss Bank) not be revealed
until a coordinated push or attack.
4. It’s not just about a few isolated persons: it could be about hijacking weak computers for part of an attack.

Submission Number: 00136

Received:12/5/2010 6:08:35 PM
Commenter: BARRYGARVIN
Organization:DISSABLED
State:South Carolina
I DON’T WANT TO BE TRACKED. IF I WANT SOMETHING ONLINE I CAN FOND IT ALONE. PUT ME ON THE LIST.
BARRY GARVIN

Submission Number: 00137

Received:12/6/2010 8:27:08 AM
Commenter: RuthCallahan
State:New York
I Support the FTC decision to stop advertisers from tracking us online. And support the “Do Not Track” list for the Internet so I can prevent marketers from tracking me.

Submission Number: 00139

Received:12/6/2010 9:36:55 AM
Commenter: ArtLang
State:Utah
I, as well as all of my friends, full support a Do Not Track System that is hard wired into the browser and reduces or eliminates on line tracking. I understand that this will greatly limit online marketeers and ad agencies from targeting me and monetizing my “eye” time but that is exactly the point. We care little for their ability to make money from our browsing interests and activity. This is nearly the same as the Do Not Call list which has been extremely successful.

Stop the tracking please !

Art

Submission Number: 00140

Received:12/6/2010 9:56:40 AM
Commenter: AndrewSolomon
State:
Dear FTC, I am writing to express my strong support for the proposed consumer protections in online activity. It is scandalous that so many firms have used consumers’ personal information (some highly confidential) without consumers’ knowledge. These companies have tried to obscure their culpability by pointing to privacy policies and opt-out mechanisms far too complex, involved, and decentralized for the average consumer to manage. Ad and search firms may argue that these proposed changes will imperil their businesses and, therefore, the pace of progress online. But these are largely self-serving and unpersuasive: companies will always find ways to remain profitable. Candidly, if a company believes that it can only stay in business by exploiting the personal information of consumers without their knowledge and consent, then those companies should not be in business. I appreciate that the FTC has taken on this challenge on behalf of consumers. So often, the FTC and other regulatory bodies are seen by the public as irrelevant or, worse yet, as “captives” of the industries that they are appointed to regulate. This proposal represents such an important step toward bolstering public trust in government, and it will form the basis for a fairer and, therefore, more sustainable internet. Many thanks, Andrew Solomon

Submission Number: 00142

Received:12/6/2010 10:35:09 AM
Commenter: JoeChampion
State:
As a consumer who has been a victim of identity theft, I strongly urge the FTC to pass the “Do Not Track” proposal and help give consumers the privacy protections that companies are unwilling to enact. Thank you.

Submission Number: 00144

Received:12/6/2010 11:10:13 AM
Commenter: GregoryByrd
State:Washington
As a family that places privacy high on its list of positive goals, we strive to limit data mining access to our online browsing. That attempt is time consuming, fraught with inconsistency and its effectiveness is always questionable.

Additionally, those unscrupulous individuals and commercial entities who employ “opt-out” icons on their websites, often do as a part of fraudulent schemes to increase collection of data, place spyware or redirect to scurrilous websites.

Instituting the proposal to provide balance for online consumer privacy interests is essential, in our opinion, and should be enacted immediately.

Our quality of life has been greatly improved by the telephone opt-out choice that we strived for. It is past time to implement the same choice for online browsing.

Enact laws that protect consumers from the invasive and harmful practice of selling our personal information without our permission. Pass legislation to allow a tough online opt-out choice now! Insure that stiff penalties for non-compliance infractions are instituted and enforced.

Thank you

Greg and Bonnie Byrd

Submission Number: 00145

Received:12/6/2010 11:22:40 AM
Commenter: Wertman
State:New York
I was horrified when I saw a pharmaceutical company medication advertiser follow me from site to site, and to forums.
Other people have access and use my computer.

I don’t want the shoes I looked at on Zappos to pop up on each site i then visit. It’s creepy and an invasion of my privacy, like some one constantly ringing my doorbell or phone after I said NO I am not interested in buying.

On the website EmpowHer, i was read info about menopause symptoms,and I then had pharmaceutical for the symptoms of menopause following me like a stalker around on line where ever I went.
Its insane to let advertisers do this to citizens.
It makes us all a “consumer” instead of a “citizen” gathering knowledge.

Submission Number: 00146

Received:12/6/2010 11:58:16 AM
Commenter: DavidCarcache
State:New York
Dear FTC Staff,

The need for consumer choice is no longer an option online unless one’s cookies are enabled, and without the FTC’s strongest measures to protect citizens, companies determined to compete in the marketplace can expose internet users to increasing privacy threats from domestic and international governments, companies, data mercenaries, outright fraud and deception.

Telcos have too much power and have consolidated their resources at the expense of the online public and it must stop. Small. mid-sized and large companies can hardly wait to aggregate this bandwidth and sell it at a premium to the highest bidder, making the opportunities rural areas could have more difficult.

More important is a rise in costs that will certainly happen for education, and a further decreased of public affair obligations to the public.

Thank you,

David
David

Submission Number: 00148

Received:12/6/2010 1:52:07 PM
Commenter: Hardt
State:Maine
I have been informing myself about the information collection techniques of internet active companies. The “tremendous benefits” to consumers are offset by the undisclosed theft of their internet and personal information. The fact is that entities unknown to me are electronically modifying the content of my computer.Cookies are one thing but when I look through my hard drive and see numerous sub directoriesnamed for websites,.sol files and other tracking files created without my knowledge or consent, I consider it the same as a telephone tap without court authorization. It is worse still because the information is being sold to second and third parties. The tremendous benefit is targeted ads?
Providing reasonable access to the consumer data they maintain is a model we have already seen with credit reporting companies. The “free credit report” we are allowed to see is usually incomplete and incorrect and there is no way to easily correct it. It is just a comon for you to buy a consumer version of their information product.
I will add more comments as I read more reports but I can tell you the only reason there isn’t legislation prohibiting these activities already is most people have no idea the extent of the tracking that sites like Facebook are doing. After you logoff and proceed to other sites, Facebook continues to monitor your internet activities.

Submission Number: 00149

Received:12/6/2010 3:12:20 PM
Commenter: ShanthiGonzales
State:California
I am in favor of a Do Not Track capability for consumers. Corporations already have too much information about their customers, which they use to manipulate their fears. If people want to receive offers and advertising, it will be easy enough for them to do that. But those of us who don’t want any additional advertising in our mental space should have the choice to opt out.

I hope that the FTC will proceed with this initiative to protect consumers.

Submission Number: 00150

Received:12/6/2010 5:47:31 PM
Commenter: SteveBrady
State:New Jersey
I would rather opt-in to features, etc., than be required to op-out. Why should the onus be on the consumer/user when it comes to privacy issues. My information should be my information and anyone who wants access to it should require my permission.

Submission Number: 00151

Received:12/6/2010 7:30:26 PM
Commenter: Leonard
State:New York
I am well beyond “computer savvy,” and I do believe that I do a fair job of protecting my privacy on the Internet. However, it is a real challlenge. I have to go through multiple levels of privacy pages on many sites and when I hear of yet another aggregator, I have to go through yet another complex dance to safeguard my information. Plain users, starting with the “computer savvy” ones have no chance. The people need protection.

Submission Number: 00152

Received:12/6/2010 10:01:14 PM
Commenter: Murphy
State:Oklahoma
I am in complete support of the “do not track” button being incorporated into browsers. I feel like this proposed addition is LONG overdue. I would like to see the scope of the restrictions broadened to include search engines as well. We would not tolerate this level of corporate intrusion anywhere else in our society, why should we here? PLEASE enact this important regulation promptly. Thank you for your consideration.

Submission Number: 00153

Received:12/7/2010 12:25:37 AM
Commenter: WilliamHumphries
State:California
To whom it may concern: I am an engineer with sixteen years experience developing applications for the web, so I am familiar with and often despair at the substantial amount of information on-line tracking tools can gather on us as we use the internet. A do-not-track registry would be disruptive to internet business models that depend on advertising revenue, however, by removing the advertising subsidy, this does create an opportunity for business that can deliver value to citizens who want to pay for those services, and re-establishes the end user and not the advertiser as the ultimate customer. But we need to plan for what this means if services people were accustomed to receiving for “free” (email, social networking, blog hosting) have to collect subscription revenues. And if we pay for those services with a credit card, we still create data that can be used to track user behavior. In the longer term, I think the direction to go is regulation of data which businesses collect from our actions online. Our laws on this are scant in comparison to other locales. We need better rules on disclosure, sharing, and sale of that information. Thank you for your consideration of this important topic. Sincerely, Wm. E. Humphries CA

Submission Number: 00154

Received:12/7/2010 1:35:16 AM
Commenter: Bayliss
State:Oregon
We need strong privacy protection for online users now. Your proposal for rule changes does not go far enough.

All users on the internet should know whether information from their home computers is being tracked with cookies and other devices. No information should be collected, retained, or manipulated by private or government parties without the specific knowledge of the internet user. Currently, and in your proposal, there is a huge amount of information taken when accessing most web sites that the user knows nothing about. When someone collects information on me without asking me or without me knowing what is collected ====== that’s spying, even if I am known on only 10 data bases as user xyz123.

If the internet user wants to give “permission” then that is fine. The user would have to know specifically what the permission given is. This would need to be spelled out in “plain English,” not like the current “I agree” forms on web sites.

Only then can each person decide:

Do I want a device put in my computer that keeps track of many of my activities without me knowing it, and then downloading that activity on a regular basis?

Do I want advertising agencies and their third party providers tracking what I like and where I go?

Do I want to take the chance that all the data collected about me, as “user xyz123” will be connected to my real name, location, and other private data?

Do I want that data massaged and sold to the government or a credit agency or insurance company?

Do I want a profile of “who I am” to exist,, forever?

If you ask most folks this, they would say “No.” So you must ask them this in plain English. And let the Googles and others lose stock value, if they don’t like the answers.

The future collation and milking of data and its subsequent use is not known to any of us at this time. We need absolute protection now, unless we specifically, and for each website, give away our privacy.

It is not spying when I know what is being recorded and by whom, and where that information is going.

Please strengthen and extend your privacy rules to dis-allow spying.

thanks!

Submission Number: 00155

Received:12/7/2010 5:00:25 AM
Commenter: Popescu
State:California
The online privacy proposals need to also address what is a lawful use of the information that has already been collected and also what the government may collect without a warrant.

Submission Number: 00156

Received:12/7/2010 10:52:30 AM
Commenter: WilliamRoberson
State:Mississippi
Please make this available! Sincerely, (signed) William D. Roberson

Submission Number: 00157

Received:12/7/2010 12:07:21 PM
Commenter: WilliamO’Konski
State:Pennsylvania
I feel that my computer is my private property. I feel violated to some extent when web sites, and other applications store info on my computer w/o my consent. I pay for the storage capacity of my machine. I don’t want others placing data on it in any way shape or form. I feel the use of data on my machine that I didn’t know was present is in fact a violation of my privacy rights. What is next? reading my thoughts w/o my permission? Do you go through a ladies purse to find information? Do you interrogate shoppers in a department store as to where else they have been? While the technology makes this easy, it is a violation!!

Submission Number: 00158

Received:12/7/2010 4:02:22 PM
Commenter: FrankPowdermaker
State:Massachusetts
I support “Do Not Track”.
Without this option there will always be abusers of the internet at the expense of innocent people.

Thanks

Submission Number: 00159

Received:12/7/2010 4:16:34 PM
Commenter: ROBERTBARNETT
Organization:N/A
State:Maryland
I BELIEVE IN YOUR PROPOSAL 100%. I SUPPORT IT ALL THE WAY. IF BUSINESSES HAVE DONE THEIR HOMEWORK THEN THEY DO NOT NEED THE FEEDBACK OF A TRACKER AND THEY CERTAINLY DO NOT NEED ANY OF MY PERSONAL INFO…

Submission Number: 00160

Received:12/7/2010 7:04:13 PM
Commenter: BassamMassoud
State:Michigan
We support the implementation of the Do Not Track program. We prefer to have privacy during our browsing of the Internet. It would be nice if they would stop tracking us!

Submission Number: 00161

Received:12/8/2010 8:07:15 AM
Commenter: EverettTownley
Organization:Workplace solutions
State:New Mexico
PLEASE implement the “DO NOT TRACK” option for consumers.
The amount of Spam generated by tracking practices currently in use clog the internet and email boxes of all of us to a ridiculous level.
anything the commission can do to enhance our privacy would be a step in the right direction.

Submission Number: 00162

Received:12/8/2010 11:20:19 AM
Commenter: EdwardJurkevics
State:Virginia
In my opinion, the FTC’s report on Protecting Consumer Privacy is a good account of the state of affairs in Internet tracking. If anything it underplays the actual and potential threat to privacy that exists today.

A frighteningly complete and accurate profile of a person’s private information, preferences, opinions and habits can be assembled by tracking networks that span many websites, and indeed tracking companies are assembling just such profiles. My views on this are as follows:

1) First, I believe I should have the right to prevent such an assemblage of private information about me without my explicit prior permission to do so.

2) It is only a matter of time until an unscrupulous company puts such private information to illegal, immoral or unethical use such as causes public outrage.

3) It is only a matter of time until such private information is stolen or leaked from a tracking company, seriously compromising a person’s privacy and exposing them to embarrassment, fraud, harassment or even violent crime.

Therefore, it is my strong opinion that a framework for DO NOT TRACK as discussed in the FTC’s report should be established by law or enforceable regulation, with criminal penalties for infraction. Furthermore browsers and other media such as Flash should require the positive granting of site-specific permission by Opting-In, as opposed to the weak, poorly documented Opt-Out regime that exists now.

The main counterarguments presented by opponents of Do NOT TRACK all run along the same line, that tracking enables website companies to sell valuable targeted advertizing, which by supporting their free-to-the-consumer business model, allows them to in turn provide valuable information, services and entertainment to the consumer. As logical and meritorious as this argument may be, it ignores the fact that a consumer’s right to privacy has been traded away, often without their knowledge. And this right to privacy is more fundamental than any benefit that can be money-measured and compared in a trade-off.

We consumers have the sense that we have a fundamental right to the privacy of information collected about us, and this right should remain unviolable unless we explicitly cede that right with a positive act of permission. The precedents are many, an example is the financial information we send to the IRS each year. The Federal Government has established an expectation of privacy among Americans.

FCC, please help consumers protect the privacy of their personal information.

Submission Number: 00163

Received:12/9/2010 11:52:15 AM
Commenter: HarryShreve
State:California
Your intentions are honorable, however, how long do you think it will be before those ya hoo’s will find a way around any law and start peeking and gathering or continue gathering information on us. Come on and get real. Give use the tools we can put on our computers so we can block out these intruders. Thank you for reading my input.

Submission Number: 00164

Received:12/9/2010 3:59:02 PM
Commenter: JosephKane
State:Maine
I think the ‘Do Not Track’ idea is excellent and I encourage its implementation. The only thing better would be to require people to have to ask to be tracked in the first place.

Tracking people on the internet (or anywhere for that matter, criminals excepted) without their permission is an unacceptable invasion of privacy.

Submission Number: 00165

Received:12/9/2010 8:16:03 PM
Commenter: AnnDupain
State:Pennsylvania
I believe there should be a tracking ban. All the money spent on Anti- virus and anti-spam programs and still my computer gets bogged down with pops ups and useless stuff. I order something then I start getting goofy emails and pop ups that I do not sign up for. I am constantly I seems like trying to find ways to block these things. Its ridiculous.

Submission Number: 00166

Received:12/10/2010 12:55:09 PM
Commenter: Robbins
State:California
another breauacity that can’t be regulated like the “do not call list”, I get 5 calls a week from contractors that just happen to be in my area, it’s like they get a one time free pass to disturb your dinner time.

Submission Number: 00167

Received:12/11/2010 7:48:30 AM
Commenter: KMcInerney
State:Maine
The goal: a simple way for the user to control whether data is collected from their browsing sessions.

The FTC can encourage all browser companies to use the same design.

Note: The idea of using 3d party-supplied “lists” that has been written up in the media is unworkable – imagine multiple lists by multiple list providers, each list being constantly updated, and the user being burdened with constantly importing long lists – and the users browser would have to read through the list each time the user went to a new site. Very confusing, inefficient.

Instead, follow the already-established paradigm wherein each browser has a “settings” or “preferences” area. The user can (optionally) control Data Collection and Cookie settings in this area.

If a given browser publisher is so “married” to their existing browser design regarding cookies and data collection, they can continue to use it, but they should be strongly urged to provide the “standardized” design – like the one below that is modelled on Opera.

***The FTC should force the control of what are called “flash cookies” to be effected from within the user’s browser, in this same area where the cookies nad data collection options are set. The control of flash data collection should not require the user to go to the Adobe web site and adjust the settings from their web site.

Using the UI paradigm from the Opera browser, this might work as follows:

Radio button choices:
0 Accept Cookies
0 Accept Cookies Only from the Site I visit
0 Never Accept Cookies

0 Accept Flash Cookies
0 Accept Flash Cookies Only from the Site I visit
0 Never Accept Flash Cookies

0 Accept All Other Data Collection
0 Accept All Other Data Collection Only from the Site I visit
0 Never Accept Data Collection

Checkbox choices:
Delete new cookies when exiting the browser
Ask me before accepting cookies

Delete new flash cookies when exiting the browser
Ask me before accepting flash cookies

Delete New data that was collected when exiting the browser
Ask me before accepting data to be collected

Cookies/Data Collection Can be Controlled Per Site:

Manage cookies, Manage Flash cookies, Manage Data Collection (these can be buttons)

** FTC should require all browsers to design a way for user to be able to select multiple cookies and/or data collection mechanisms and delete the selected them at once, rather than having to delete each one at a time.
User may have accumulated many hundreds of items and desire to keep/allow only a few.
The list that displays should include a “select all” check box at the top of the list, as well as a checkbox for each item in the list, with the ability to multiply or singly select, and delete.

Submission Number: 00168

Received:12/11/2010 11:50:03 AM
Commenter: EdgarDworsky
Organization:Consumer World
State:Massachusetts
By way of background, I am a former Assistant Attorney General in Consumer Protection in Massachusetts, have been a consumer advocate for the past 33 years, and run a number of consumer education websites, including ConsumerWorld.org .

I think there are some categories of individuals, organizations, and businesses that should be exempt from the proposed rules. Generally speaking, individuals with websites, bloggers, small organizations, small businesses, and anyone whose site resides on a shared server or utilizes commercial services aimed at such audiences providing hosting services or hosting software (such as wordpress, wordpress.com, blogger.com, geocities-like services, facebook, etc.) should be exempt from these rules. While the Facebooks of the world should be covered, the individuals that use their platform should not be, for example.

These individuals and entities have little or no control over the software platform that operates their websites, nor over the servers on which their sites reside. For example, a blog hosted at wordpress.com may deliver advertising targeted to users based on IP address, cookies, or other criteria, and the owner of the blog has neither access to nor control over that. It also cannot control what information the underling server collects and how others might use it. In addition, the individuals and entities suggested above for exemption may have little technical expertise to implement any proposed requirements, nor have in-house staff with those capabilities. Cost would be an issue here too.

The underlying software companies used for blogs, for example, and the companies providing hosting services, should be the entities responsible for conforming their products, services, and servers to meet the requirements of any “do not track” rules, including making those things aware of choices individuals may make in their browser settings.

In terms of commonly accepted practices that should be exempt from regulations, let me use ConsumerWorld.org as an example. I cannot control what information is collected by the shared server on which ConsumerWorld.org resides. I may have access to it through various reporting tools, however. I have a limited number of affiliate links in Consumer World, such as ones where users can sign up for Consumer Reports. I cannot control whether those links place cookies on the consumer’s computer, or what other data those links generate or use. If I used “Google Ads”, I similarly cannot control what is displayed or collected data-wise. To not annoy regular readers with pop-up ads for my free newsletter, I use a cookie to limit the showing of those ads to regular users. I cannot control whether the cookie is or is not placed based on some choice the reader may make in their browser. When I run a survey, the script I use collects IP addresses so a person cannot vote twice. I cannot control whether it collects that data based on an individual choice any particular visitor to the site may make or establish in his or her browser. I collect email addresses of those who wish to subscribe to the newsletter, and follow applicable CANSPAM rules.

All these actions, and the bits of data collected, I would argue should be “commonly accepted.” To the extent the underlying website software (if other than hand coded), server software, and browser settings can be required to work together to automatically reflect the consumer’s choices, all the better. I have neither the technical expertise myself nor the financial ability to hire someone to do this. I suspect this would be true for the majority of non-large businesses that really don’t use the data collected nor employ explicit tracking systems to better market their products to individuals.

I urge the FTC to differentiate individuals, small businesses and organizations from businesses that utilize tracking tools and networks to deliver targeted ads, build customer profiles, and mine personal data.

Submission Number: 00169

Received:12/11/2010 8:58:39 PM
Commenter: ChristopherWelch
State:Virginia
While a “Do Not Track” option in a browser is all good and well the FTC has not done enough to protect people’s online privacy in a more comprehensive way. What is needed is strict rules that limit not only companies and private interests access to people’s browsing habits and personal information but also policies that keep the government from doing the same thing. Another issue is the fact that once a company like Verizon has my social security number, which they require in order to set up an account, another dubious practice, there is no law stating they have to delete all of my information once I quit being a Verizon customer. I don’t want some profit seeking company like Verizon being allowed to keep my personal info around forever, selling it to any third party who can get their hands on it. There needs to be limits to what companies can and can’t keep around. Furthermore there needs to be strict fines or punishments for the usage of that data for purposes other then the setting up of the account or the rendering of services. I don’t want my mailing address or phone number being sold to third parties without my express permission. That permission needs to be solicited not in the fine print but in a separate page with a check mark box asking if I would be willing to share that with the companies partners or affiliates. If I click NO, then that’s that. If my number gets sold after that from that company they would have actively broken the law and could be fined or sued. This is where we as a nation need to be heading if we truly want internet privacy to be a reality. There needs to be clear cut laws that prevent my information from being stored without my approval. If it is to be stored because it is necessary to verify I am who I say I am it needs to be stored in an encrypted manner. Also there is no reason companies like Verizon should ever have my social security number, there are other ways to verify my identity. The only people who should be able to require me to submit a Social Security Number is the US Government, that it. While we can never completely control data once it gets out into the internet, we should be working to limit its dispersal by profit seeking entities who care nothing for my privacy.

Submission Number: 00170

Received:12/12/2010 8:46:12 AM
Commenter: JohnMcInerney
Organization:Lone Grouse
State:Vermont
Please support a silent majority voter and ensure that I will be able to control whether any site can track any information about me and my browsing. I think the controls related to web tracking should be built into the web browsers and should be easy to find, and easy to understand and use.

Submission Number: 00171

Received:12/12/2010 11:56:02 AM
Commenter: ThomasMcDonald
State:Pennsylvania
As a consumer, I am very dissapointed with the FTC’s approach to “privacy” since it is not focusing on personal identifiable and sensitive information. I am more concerned about someone unknowningly tracking or collecting my sensitive data (e.g, name, address, health records, social security number, credit cards). I am a recent victim of identify theft. I could careless if someone knows I am shopping for an Ipad or have interest in a buying a car.

Please focus your attention on guarding the privacy of my personal information, not my internet shopping habits.

Submission Number: 00172

Received:12/12/2010 12:46:34 PM
Commenter: carlmcinerney
State:Vermont
Please ensure that I will be able to control whether any site can track any information about me and my browsing. I think the controls related to web tracking should be built into the web browsers and should be easy to find, and easy to understand and use.

Submission Number: 00173

Received:12/12/2010 2:12:31 PM
Commenter: Ferguson
State:Vermont
I am very much against the tracking of web browsing and consider it an invasion of privacy.

Submission Number: 00174

Received:12/12/2010 6:42:06 PM
Commenter: HelenBalgooyen
State:Maine
Please ensure that I will be able to control whether any site can track any information about me and my browsing. I think the controls related to web tracking should be built into the web browsers and should be easy to find, and easy to understand and use.

Submission Number: 00175

Received:12/12/2010 7:09:39 PM
Commenter: SaraWilder
State:Maine
Please ensure that I will be able to control whether any site can track any information about me and my browsing. I think the controls related to web tracking should be built into the web browsers and should be easy to find, and easy to understand and use. Thank you.

Submission Number: 00176

Received:12/13/2010 5:21:59 AM
Commenter: Farnsworth
State:Maine
Please ensure that I will be able to control whether any site can track any information about me and my browsing. I think the controls related to web tracking should be built into the web browsers and should be easy to find, and easy to understand and use.

Submission Number: 00177

Received:12/13/2010 5:58:44 AM
Commenter: norris
State:New Jersey
Please pass the DO NOT TRACK.

Submission Number: 00178

Received:12/13/2010 8:46:02 AM
Commenter: LucetteDeMichele
State:Maine
Please ensure that I will be able to control whether any site can track any information about me and my browsing. I think the controls related to web tracking should be built into the web browsers and should be easy to find, and easy to understand and use.

Submission Number: 00179

Received:12/13/2010 10:55:37 AM
Commenter: JamesDucharme
State:Michigan
I fully support the creation of a “Do Not Track” system for computer web browsers. My personal information and browsing habits should be private, not freely taken without my permission. The Do Not Call registry has been a huge success. It is time to initiate the Do Not Track registry. Merry Christmas! Jim

Submission Number: 00180

Received:12/13/2010 12:31:18 PM
Commenter: MartinBalikov
State:Washington
As a practicing consultant on Geographic Information Systems I am concerned that the recommendations in the preliminary report “Protecting Consumer Privacy in an Era of Rapid Change” does not address the needs of public agencies to collect, maintain, use and, in a more limited manner publish, location information. The recommendations to restrict collection of “precise geolocation data” needs to look beyond the risk to the public from involuntary collection of location to accomodate intentional use, such as reporting street light outage, pothole location or emergencies, as well as the needs of the professional geospatial community. Before moving forward a clear definition of what is to be included under “precise geolocation data” needs to be provided and the geospatial community should be consulted for direct input to far reaching policy changes.

Submission Number: 00181

Received:12/13/2010 1:04:43 PM
Commenter: Williams
State:Idaho
I believe this would be a good idea. This will help prevent selling of online data collected. If it works like Do not call list – it is a waste of time. If it has a year and has to be renwed like Do not call do not waste government time or money. If I sign up it should be good unless the person wwants to revoke it. This would be very helpful for elderly who get trapped giving out information.

Submission Number: 00182

Received:12/13/2010 3:09:55 PM
Commenter: LauraPatterson RN
State:Maine
Please ensure that I will be able to control whether any site can track any information about me and my browsing. I think the controls related to web tracking should be built into the web browsers and should be easy to find, and easy to understand and use. Thank you

Submission Number: 00183

Received:12/13/2010 4:02:30 PM
Commenter: ChristopherMcGratty
State:Texas
As with the unfettered salaries of professional athletes, if we are not provided with PROTECTION from Being Tracked on the Interenet, then will will continue to lose our right(s) of freedom of choice. We respectfully request that the FTC demand by law the right for consumers to “OPT OUT” and to be Protected from being Tracked while on the Tnternet. A similiar program was enacted very successfully for “No Call List” and we should have the same right while browsing the Internet. Thank you. CFMcG TX.

Submission Number: 00184

Received:12/13/2010 4:25:41 PM
Commenter: ChrisMcGratty
State:North Carolina
Please ensure that I, the end user, can and will have complete control in regards to whether or not a website can track my browsing habits and/or any associated personal information without my knoweldge. The controls related to web tracking should be built into the web browsers and should be easy to find, and easy to understand and use.”) It is safe to say the majority of web surfers have minimal understanding on how to enable/disable the simplest of features so this needs to be blatently obvious. While there are some conveniences to storing some information, cookies and other web-bots typically only serve the corporation who is receiving the information and one only knows what is really done with it or who sees it.

Submission Number: 00185

Received:12/13/2010 4:29:00 PM
Commenter: JessciaMcGratty
State:North Carolina
Please ensure that I, the end user, can and will have complete control in regards to whether or not a website can track my browsing habits and/or any associated personal information without my knoweldge. The controls related to web tracking should be built into the web browsers and should be easy to find, and easy to understand and use.”) It is safe to say the majority of web surfers have minimal understanding on how to enable/disable the simplest of features so this needs to be blatently obvious. While there are some conveniences to storing some information, cookies and other web-bots typically only serve the corporation who is receiving the information and one only knows what is really done with it or who sees it.

Submission Number: 00186

Received:12/13/2010 10:00:52 PM
Commenter: CarolineNye
Organization:CJ Nye
State:New York
I am deeply concerned with the lack of controls available on the latest iteration of facebook, for reasons beyond my privacy in regards to marketing. I am concerned for my safety. My chief concern is that now anyone that I do not specifically block, can see the full breadth of comments I make on colleagues pages, or they on mine. I have had stalker issues, so it is no idle concern.

This, though seemingly personal, is I believe, still the purview of the FTC, because facebook has become an indispensable networking tool (a public good that I believe has precedence in both the recent blackberry debacle, as well as the copyright law’s standard of iconic status), and, as I said in my letter to the Council of Women and Girls on the same subject, women are already disadvantaged in the workforce- facebook making it nearly impossible to maintain a professional network and safeguard myself is tantamount to asking me to choose between my fiscal and physical well-being. This is not a choice I should need to make for the sake of their marketing dollars as an otherwise vulnerable member of society. It is, to my mind, an inexcusable breach of ethics for the sake of commerce.

Please see fit to weigh that public good, my good, against the profits of a single segment of commerce.

Best~ CJ Nye

Submission Number: 00187

Received:12/14/2010 9:31:49 AM
Commenter: SashaRomanosky
Organization:Carnegie Mellon University
State:Pennsylvania
Greetings, There has been much discussion regarding both the consequences and benefits of requiring companies to notify individuals when their information has been lost or stolen. In an updated analysis of the effect of these US state data breach disclosure (security breach notification) laws, we use consumer-reported identity theft data from the FTC, over the years from 2002-2009 and we find that laws have, indeed, reduced identity theft by 6%. While it is difficult to qualitatively evaluate this reduction (i.e. is it good? Is it enough?) we believe this is a positive result and we welcome the opportunity to share these results with this Committee. Moreover, we believe it is the only study that attempts to rigorously evaluate the effect of these laws on consumer outcomes. The full paper is available at http://ssrn.com/abstract=1268926 and the citation is: Romanosky, Sasha, Telang, Rahul and Acquisti, Alessandro, Do Data Breach Disclosure Laws Reduce Identity Theft? Forthcoming in the Journal of Policy Analysis and Management, 2011. cheers, Sasha Romanosky

Submission Number: 00188

Received:12/14/2010 4:23:31 PM
Commenter: BrianWatson
State:Oregon
Just a quick note to say I fully support the FTCs efforts to enforce privacy. The Do Not Track functionality sounds like it could work and would take significant steps toward addressing privacy issues on the internet.

I would add that I feel the best way to handle opt-in or opt-out is to have the default be complete privacy, with the consumer needing to explicitly opt-in in order to give permission for their data to tracked or used. There are far too many “you-must-click-ok-to-use-this” types of things out there, and while people should read them and investigate their options, the reality is very few actually do. Therefore, if informed consent is deemed to have occurred during such a click, most consumers would be unaware they have agreed to let their information and activities be tracked and used. Hardly “informed” consent at all.

Submission Number: 00189

Received:12/14/2010 6:34:41 PM
Commenter: stringfellow
State:Florida
I agree with some of the blogs out there. Consumers should have the opt-in or opt-out choice for online tracking either by tracking cookies, keyed in data online at various websites, or by other electronic means & the hosted website need to explain the policy in simple term without all the legal terms that most consumers do not understand. A brief check box that includes a short summary of the options should be included. It’s not the government or the web vendors’ responsible to spell it out for everybody, but the language of the opt in, or opt out should be simple.

Submission Number: 00190

Received:12/15/2010 7:35:47 AM
Commenter: MichaelMiller
State:Iowa
My online privacy and that of my employees and clients is of utmost importance. For far too long we have allowed online entities to track our movements and preferences, profiling our every turn on the Internet.

If someone were to physically follow you around within a department or grocery store, tracking your every move and documenting everything that you looked at or purchased, you would be appalled, as would I. What I look at, read or purchase on the Internet should be of no concern to anyone else but me, and possibly the online entity that I purchased it from.

It is high time that our right to privacy be upheld as our fore Fathers envisioned, including our Internet activity. That is why I am a devout supporter of the “opt-in” proponent.

And, if by chance the FTC is tracking my location via my IP address, then shame on you.

Submission Number: 00191

Received:12/15/2010 9:00:43 AM
Commenter: martinnemzow
State:Florida
Attachments: 00191-57181.pdf Size: 42 KB DoC: Requiring Personal PII Ownership.pdf
Privacy proposal is bandaid to more significant technical problems regarding security and privacy in terms of forced reidentification, aggregation of source PII, and definitional deficits as to what information endangers the individual. Even DATA ACT under consideration fails to reflect need to define PII and assert its ownership to the individual and enable the individuals with the ability to enforce informational rights to identity. Attached file explains in clear layman terms need for requirement of personal PII ownership to make significant positive benefits in privacy landscape.

Submission Number: 00192

Received:12/16/2010 10:28:27 AM
Commenter: ColinWatson
Organization:Watson Hall Ltd
State:Outside the United States
Maintain comprehensive data management procedures
————————————————-
The UK’s ICO published a report on creating the business case and includes a section on how organisations should consider the value of PII from more than one perspective. (I was co-author).

The Privacy Dividend, ICO
http://www.ico.gov.uk/upload/documents/library/data_protection/detailed_specialist_guides/privacy_dividend.pdf

Commonly accepted practices
—————————
Whilst websites and other information systems could prevent logging of certain data, what data exactly is within scope… e.g. IP address, user agent, user name. Normal logging could exclude certain data, but in the event of errors, suspicious or malicious activity, organisations should be allowed to record, retain and analyse information – some of which could then include personal data (e.g. an IP address which could be used to identify one person). Guidance should not exclude such information gathering, but of course that data needs to be handled securely and destroyed at the end of its use.

Improved privacy notices
————————
The UK’s ICO has produced an excellent guide in this area – relevant to UK legislation. The ICO prefers the term “privacy notices” to “privacy statement” or “privacy policy”. It may be useful to reference it in the FTC report as a good example elsewhere:

Privacy Notices Code of Practice, ICO
http://www.ico.gov.uk/upload/documents/library/data_protection/detailed_specialist_guides/privacy_notices_cop_final.pdf

Reasonable access to consumer data
———————————-
Additional labelling of product/service ownership would assist consumers identifying their rights and who to contact. Some discussion of this on my blog:

Trust .UK
http://www.clerkendweller.com/2010/12/14/Trust-UK

Submission Number: 00193

Received:12/18/2010 4:29:30 PM
Commenter: Wood
State:Vermont
Please ensure that I will be able to control whether any site can track any information about me and my browsing. I think the controls related to web tracking should be built into the web browsers and should be easy to find, and easy to understand and use.

Submission Number: 00194

Received:12/20/2010 4:34:52 PM
Commenter: Hager
State:North Carolina
I support letting online users opt out of having their information tracked. I do not think it would be realistic to let advertisers themselves determine how they plan to follow the regulations. I am particularly concerned about health related information being tracked and made available to insurance companies or potential employers.

Submission Number: 00195

Received:12/23/2010 11:47:58 AM
Commenter: StuartIngis
State:District of Columbia
Attachments: 00195-57218.pdf Size: 46 KB
00195-57219.pdf Size: 25 KB DoC: Ingis_Letter.pdf Ingis-ExtensionRequest.pdf
Please find attached a request by industry trade associations for an extension of time to comment.

Submission Number: 00196

Received:12/24/2010 1:59:36 PM
Commenter: Allen
State:Missouri
To whom it may concern:

I am exceedingly opposed to _ANY_ type of tracking. We should not have to be bothered with either “opting in” or, worse yet, having to “opt out”. Should any type of tracking be allowed (which it most definitely should NOT!) it should have complete and total transparency where each and every entity who does the tracking _MUST_ inform the ‘trackee’ _BEFORE_ tracking may start AND include extremely explicit instructions on how to “opt out”. That said, this “opt out ‘cookie'” is a pathetically feeble approach to truly stop the tracking process since that cookie will be destroyed when one clears ones computer of all cookies unless they are tech savvy enough to know how to keep it/them.

In addition to which, each entity who tracks will have their own cookie. I for one do _NOT_ want my valuable hard drive space taken up with any number of cookies that are not absolutely necessary for my computer to be able to ‘talk’ with another computer! I do _not_ want my valuable _time_ taken up having to “opt out” every time I click my mouse! This would be extremely counterproductive, to say the least!

There is a company who has a _STUPENDOUS_ idea to give people the control (that we have the right to) over the data that is put on our own machines. This idea is one exceptionally good way to simply add a header indicating the user/owner of that machine wishes to not be tracked. I believe that barring a move to prevent any tracking at all by any entity this method could very easily be quite viable … _providing_ the general basically computer illiterate end user has this method put squarely in front of their understanding with extreme ease and simplicity of implementation being held mandatory.

In my “perfect world” we would once again have freedom of movement without any type of device watching us. This returned freedom would include, but is not limited to, having complete anonymity on the internet where only our machines know which machine is talking to which _ONLY_ for the purpose of that ‘mechanical conversation’ while it is transpiring, not being listened to on the telephone by algorithms, etc., not having traffic cameras watching any and all turns we take on the road and/or all the other ways our daily lives are being scrutinized and our privacy being invaded upon. Oh, how I long for the good old days before all of this tracking, spying, and surveillance …whatever one wants to call it… came to pass.

Thank you for hearing “We The People” out. After all, _we_ pay your salaries with our hard earned tax dollars. I hope with my strongest hopes that you actually use this information to curtail the rampant greed that has facilitated the necessity for your proceedings in this matter.

Sincerely,
A extraordinarily concerned natural born United States citizen who believes in our Constitutionally given Right to Privacy.

Submission Number: 00197

Received:12/24/2010 7:14:25 PM
Commenter: Crooki
State:Missouri
I believe that the proposed do-not-track mechanism is a bad idea because it implies that tracking is acceptable in the absence of specific declaration.

Instead, you should standardise a please-track-me mechanism, for people wishing to be tracked. The mechanism may include a client-generated unique id number to make tracking even easier for the parties the client has chosen to allow.

Once this mechanism is widely avaliable to consumers, any tracking performed in the absence of the please-track-me token may be made punishible by fine.

Submission Number: 00199

Received:12/28/2010 12:39:23 PM
Commenter: PhilipBereano
State:Washington
Yes, finally. Consumers should be able to bar sites from keeping track of their activities. it is an elemental aspect to privacy, definitely needed in this era of enhanced data collection/correlation possibilities.

Not all info is equally sensitive, but there is definitely sensitive info revealed by a track of one’s website visits. Only the individual should be able to control there being a record of such activity.

All of this comment may be made public, except for my email address

Submission Number: 00200

Received:12/29/2010 6:46:33 AM
Commenter: PhilippaStrum
Organization:City University of New York
State:District of Columbia
The proposed “Do Not Track” mechanism is a very welcome idea, and one that is much needed to protect consumer privacy. The accumulation of data about what individuals look at and what they choose to buy, by businesses, endangers the kind of control over one’s personal information that Americans rightly take for granted. I very much hope this proposal will be adopted.

Submission Number: 00201

Received:12/29/2010 8:37:56 AM
Commenter: JoshuaMcNary
Organization:Aerial Services, Inc. (ASI)
State:Iowa
I respectfully urge the FTC not to implement any enforcement or broad regulation that would have a harmful affect on firms like mine in the broad private geospatial community.
Specifically, the FTC report imprecisely uses and regulates the term “precise geolocation information” or “precise geolocation data”. This would adversely impact consumers, geospatial firms, and government programs. My firm is particularly concerned that this term was not defined in the FTC staff report and the proposed regulations will have broad and harmful unintended consequences.

The use of the term “geolocation” or other geospatial relevant terminology that appear in the FTC regulations will impose a significant new liability on my firm. It regulates areas of the economy and geospatial activities that have not been identified as a problem or pose any privacy concern to citizens.

The regulations could thwart common, legitimate, and emerging uses of geospatial data for emergency response/post disaster remediation, insurance, environmental protection, E-911 & ambulance services, fleet management broadband mapping, home security, navigation, mortgage foreclosure monitoring/early warning system, and others.
Moreover, activities, technologies, and applications development could be deemed illegal. For example, it would be impractical, if not impossible, for my firm to obtain prior approval or consent from individual citizens prior to acquiring or applying data such as satellite imagery, aerial photography, or parcel, address, or transportation data. The FTC regulation would effectively ban my firm, or our clients, from important value- added, integration and application activities.

Finally, any such FTC regulation could put U.S. companies at a significant and insurmountable competitive disadvantage against foreign firms that may not be covered by that regulation, or for which enforcement would be impractical.

FTC should provide the necessary and desirable privacy protections to individual citizens; however, it should not limit the geospatial community’s ability to grow, prosper, and bring to the market those technologies and applications that meet the economic demands of consumers and citizens.

Submission Number: 00202

Received:12/29/2010 9:09:56 AM
Commenter: MikeTully
Organization:Aerial Services, Inc.
State:Iowa
I respectfully urge the FTC NOT implement the proposed regulation. It will have a harmful affect on firms in the private geospatial community and impose unneeded, harmful, and over-reaching Federal regulations on citizens and businesses.

Specifically, the FTC report uses the term “precise geolocation information” or “precise geolocation data”. This term must not be used without “precise” definition. DROP the term. Using it will would adversely impact consumers, geospatial firms, and government programs. My firm is particularly concerned that this term was not defined in the FTC staff report and the proposed regulations will have broad and harmful unintended consequences.

The use of the term “geolocation” or other geospatial relevant terminology that appear in the FTC regulations will impose a significant new liability on my firm. It regulates areas of the economy and geospatial activities that have NOT been identified as a problem or pose any privacy concern to citizens.

The regulations could thwart common, legitimate, and emerging uses of geospatial data for emergency response/post disaster remediation, insurance, environmental protection, E-911 & ambulance services, fleet management, mapping, home security, navigation, mortgage foreclosure monitoring/early warning system, and others. Moreover, activities, technologies, and applications could be deemed illegal. For example, it would be impractical, if not impossible, for my firm to obtain prior approval or consent from individual citizens prior to acquiring or making products or providing services using data such as satellite imagery, aerial photography, or parcel, address, or transportation data. The FTC regulation would effectively ban my firm, or our clients, from important value-added, integration and application activities.

Finally, any such FTC regulation could put U.S. companies at a significant and insurmountable competitive disadvantage against foreign firms that may not be covered by that regulation, or for which enforcement would be impractical.

FTC should provide limited and reasonable privacy protections to individual citizens; however, it should not use the undefined term “precise geolocation” and limit the geospatial community’s ability to grow, prosper, and bring to the market those technologies and applications that meet the economic demands of consumers and citizens.

Submission Number: 00203

Received:12/29/2010 12:27:52 PM
Commenter: Kelsay
State:Missouri
A person should have the ability to setup a privacy or advertising profile on their computer, that shows only the data about themselves that they wish to allow websites to see. We all know that they want to know as much demographic data about us as possible, so a list of interests that a person could select should be a part of this profile. If I CHOOSE to give my age, weight, birthdate, shoe size, etc and my interest in gardening, target shooting, pottery and flip-flops, then I can set this up when I first setup the browser or the computer and have access to change it as my interests change. I should also be able to see a list of root websites that have accessed the info like I see my internet history. If the advertisers want us to be open, then they need to be open and stop sneaking around. Many things that advertisers do such as obfuscation of their address appears to me to seem criminal in nature.

Submission Number: 00204

Received:1/3/2011 2:55:15 PM
Commenter: RLong
State:Michigan
I SUPPORT “a framework to balance the privacy interests of consumers with innovation that relies on consumer information to develop beneficial new products and services. The proposed report also suggests implementation of a “Do Not Track” mechanism”.

As a consumer, I want to control who has information about me and I’d like to know how it is used. I do not believe that the industry will regulate itself in a way that benefits the consumer. Similar to US Postal and telephone opt-out, I want the option to do so for my online activity.

Submission Number: 00205

Received:1/4/2011 9:29:07 AM
Commenter: JohnByrd
Organization:MAPPS
State:Virginia
Attachments: 00205-57236.pdf Size: 119 KB DoC: MAPPS Letter to Dept of Commerce (1-28-11).pdf
Please find the attached letter from MAPPS to the FTC.

Submission Number: 00206

Received:1/4/2011 9:33:29 AM
Commenter: JeanDeschene
State:Massachusetts

I support the initiative to opt-out of being tracked on the internet. This is very similiar to the “do not call” list which has been effective, except for non-profit and governmental entities. Please
provide the means to all citizen to exercise their right to privacy. The job of the FTC is front and foremost to act in behalf of the citizens best interests before they consider marketing and corporate interests.

Submission Number: 00207

Received:1/6/2011 8:43:49 AM
Commenter: JohnErnst
Organization:Survey Systems of America, Inc
State:Illinois
I respectfully urge the FTC not to implement any enforcement or broad regulation that would have a harmful
affect on firms like mine in the broad private geospatial community.
Specifically, the FTC report imprecisely uses and regulates the term “precise geolocation information” or
“precise geolocation data”. This would adversely impact consumers, geospatial firms, and government
programs. My firm is particularly concerned that this term was not defined in the FTC staff report and the
proposed regulations will have broad and harmful unintended consequences.
The use of the term “geolocation” or other geospatial relevant terminology that appear in the FTC regulations
will impose a significant new liability on my firm. It regulates areas of the economy and geospatial activities
that have not been identified as a problem or pose any privacy concern to citizens.
The regulations could thwart common, legitimate, and emerging uses of geospatial data for emergency
response/post disaster remediation, insurance, environmental protection, E-911 & ambulance services, fleet
management broadband mapping, home security, navigation, mortgage foreclosure monitoring/early warning
system, and others.
Moreover, activities, technologies, and applications development could be deemed illegal. For example, it
would be impractical, if not impossible, for my firm to obtain prior approval or consent from individual citizens
prior to acquiring or applying data such as satellite imagery, aerial photography, or parcel, address, or
transportation data. The FTC regulation would effectively ban my firm, or our clients, from important valueadded,
integration and application activities.
Finally, any such FTC regulation could put U.S. companies at a significant and insurmountable competitive
disadvantage against foreign firms that may not be covered by that regulation, or for which enforcement would
be impractical.
FTC should provide the necessary and desirable privacy protections to individual citizens; however, it should
not limit the geospatial community’s ability to grow, prosper, and bring to the market those technologies and
applications that meet the economic demands of consumers and citizens.

Submission Number: 00208

Received:1/6/2011 9:16:23 AM
Commenter: WilliamWhitworth
Organization:Whitworth & Associates, Inc.
State:South Carolina
“This proposal (like legislation that was introduced but not acted upon by Congress) uses the very broad term ‘precise geolocation data’ but does not define the term. This is very dangerous. Also, to require that any geospatial firm get ‘affirmative express consent’ from every citizen about whom precise geolocation data is to be collected is impractical to the point of being impossible. This is not just data about an individual but any ‘precise geolocation data.’ This would require every citizen to be contacted and approval obtained before parcel data is collected, or imagery, or elevation data or any other geolocation data.”

Submission Number: 00209

Received:1/6/2011 9:45:49 AM
Commenter: WesleyKeller
Organization:City of Universal City
State:Texas
Page 61 Last paragraph of the report.

The proposed rule-making could have unintended consequences:

Would precise geolocation include land surveying in terms of platting requirements? Plats are public documents required by municipalities and local government. Platting commonly provides precise geolocation information.

Would it include records kept by tax appraisal districts? Title research and land surveying use the records to establish title, and research land records prior to a survey.

Would it include deed and plat records maintained by counties. Land surveyors rely on these records to do their jobs. These records are commonly maintained electronically.

What about aerial photography? Would a company have to receive permission from all the people within the coverage area of the photo?

Most of this information is retained in some form of electronic file or document. The need to share this information is intrinsic to the fields of remote sensing, photogrammetry, geographic information systems, land surveying, engineering and others.

There are privacy concerns with products such as Google Maps and Google Earth, but the benefits greatly outweigh those concerns.

Even personal geolocation is problematic: location information maintained by private telecommunications firms is used by first responders to respond to 911 calls in areas away from the home.

Most telecommunications devices allow the consumer to “turn off” the location features of the phone.

“Precise geolocation” needs a narrow definition. Perhaps something along the line of precise geolocation for the express purpose of tracking individual persons.

Thank you for your time.

Wes Keller

Submission Number: 00210

Received:1/6/2011 10:47:33 AM
Commenter: BruceJohnson
Organization:B Johnson Services, LLC
State:North Dakota
I respectfully urge the FTC not to implement any enforcement or broad regulation that would have a harmful affect on firms like mine in the broad private geospatial community. Specifically, the FTC report imprecisely uses and regulates the term “precise geolocation information” or “precise geolocation data”. This would adversely impact consumers, geospatial firms, and government programs. My firm is particularly concerned that this term was not defined in the FTC staff report and the proposed regulations will have broad and harmful unintended consequences. The use of the term “geolocation” or other geospatial relevant terminology that appear in the FTC regulations will impose a significant new liability on my firm. It regulates areas of the economy and geospatial activities that have not been identified as a problem or pose any privacy concern to citizens. The regulations could thwart common, legitimate, and emerging uses of geospatial data for emergency response/post disaster remediation, insurance, environmental protection, E-911 & ambulance services, fleet management broadband mapping, home security, navigation, mortgage foreclosure monitoring/early warning system, and others. Moreover, activities, technologies, and applications development could be deemed illegal. For example, it would be impractical, if not impossible, for my firm to obtain prior approval or consent from individual citizens prior to acquiring or applying data such as satellite imagery, aerial photography, or parcel, address, or transportation data. The FTC regulation would effectively ban my firm, or our clients, from important value-added, integration and application activities. Finally, any such FTC regulation could put U.S. companies at a significant and insurmountable competitive disadvantage against foreign firms that may not be covered by that regulation, or for which enforcement would be impractical. FTC should provide the necessary and desirable privacy protections to individual citizens; however, it should not limit the geospatial community’s ability to grow, prosper, and bring to the market those technologies and applications that meet the economic demands of consumers and citizens. Thank you for allowing me to comment on this proposed rule.

Submission Number: 00212

Received:1/6/2011 1:16:36 PM
Commenter: BruceSmith
Organization:Alpine Enterprises Inc
State:Idaho
Consumer Privacy

This proposal needs better definitions to keep from impacting Private Surveyors. We have prepared a lot of GIS Data for our County through FEMA Disaster Preparedness Grants, and it has been determined that it is public information. It is very important to Emergency Services, and I use geospatial data daily to better serve my clients.

Please reconsider this proposal.

Submission Number: 00213

Received:1/6/2011 3:22:13 PM
Commenter: MelanieBenda-Joubert
State:Rhode Island
I am concerned about the policy that you are attemping to enact. the terms that you are using are very general in nature (ie. “precise geolocation data”) and can define many different things in the surveying and geospatial industries. I strongly urge you to rewrite this policy to properly define industry terms and to create a policy that provides public privacy protection while not unintentionally including broader implications to either the surveying or geospatial industries.

Submission Number: 00214

Received:1/6/2011 5:14:41 PM
Commenter: PLarkin
State:Idaho
Please define “precise geolocation data” before voting on this legislation.

Submission Number: 00215

Received:1/6/2011 8:12:36 PM
Commenter: MelissaMacGregor
Organization:SIFMA
State:District of Columbia
Attachments: 00215-57251.pdf Size: 80 KB DoC: SIFMA Comment Letter – Commerce FTC – 1-31-11.pdf
Please see the attached letter requesting additional time to comment.

Submission Number: 00216

Received:1/6/2011 9:50:48 PM
Commenter: JamesCook
Organization:James Cook, RPLS
State:Arkansas
Sounds like another reach for control of America By the Democrats. If Obama cannot get the legislation passed in congress he makes a rule to get it done. I will watch this closely. I am a Tea Party Member

Submission Number: 00217

Received:1/7/2011 8:00:51 AM
Commenter: AlvaroVega
State:New York
the broad picture tells me that utilities are going to have a higher cost in operations and the customer will ultimately will be hit with that cost, to get any kind of construction done surveying and mapping is required to have more impediments added to the planning stage its going to hurt the bottom line of utilities and the customer.

Submission Number: 00218

Received:1/8/2011 9:06:45 AM
Commenter: DougSchneider
Organization:Rick Engineering Co.
State:Arizona
I would agree with John Palatiello’s statement quoted below.

“There are two major problems with this proposal,” said John Palatiello, executive director of MAPPS. “This proposal (like legislation that was introduced but not acted upon by Congress) uses the very broad term ‘precise geolocation data’ but does not define the term. This is very dangerous. Also, to require that any geospatial firm get ‘affirmative express consent’ from every citizen about whom precise geolocation data is to be collected is impractical to the point of being impossible. This is not just data about an individual but any ‘precise geolocation data.’ This would require every citizen to be contacted and approval obtained before parcel data is collected, or imagery, or elevation data or any other geolocation data.”

Care must be taken not to adversely affect data acquisition for legitimate purposes.

Thanks for your consideration,

Doug Schneider
Professional Land Surveyor
Associate
Rick Engineering Company

Submission Number: 00219

Received:1/9/2011 6:00:31 PM
Commenter: MarkWittow
Organization:American Bar Association, Intellectual Property Law Section
State:Washington
I am writing on behalf of the Intellectual Property Law (IPL) Section of the American Bar Association (ABA), to request an extension of time, to March 15, 2011, to comments on the FTC’s Report on “Protecting Consumer Privacy in an Era of Rapid Change: A Proposed Framework for Businesses and Policymakers.” Members of the IPL section have been working actively to develop comments, but need more time to do so and to coordinate the submission of comments with other interested sections of the ABA, specifically the Science and Technology, Business Law and Individual Rights & Responsibilities sections. The additional time will allow for better coordination among the various interested ABA sections as well proper consideration by the leadership of the ABA IPL section.

This extension request is authorized by Marylee Jenkins, chair of the IPL Section of the ABA.

Submitted by Mark Wittow, chair of the ABA IPL section’s Information Technology Division.

Submission Number: 00220

Received:1/10/2011 12:57:51 PM
Commenter: GerardAshton
State:Vermont
The list of proposed “commonly accepted practices” in V C 1 is deficient in not defining “consumer”, too narrow in assuming that the consumer has sought goods or services from the business, and should be expanded to include public purposes even if there is no business relationship between the business collecting the data and the person described in the data. Public purposes may include land records used to determine ownership of land, improvements on land, land boundaries, and real estate tax information, building permits, and location data in emergency dispatching databases. The data to be collected may be specified by state and local government whether in real estate related laws and regulations, or standards of practice for engineers, architects, and skilled trades. The data may also be specified in standards from recognized standards-making organizations, whether public or private, such as the American Land Title Association.

The lack of a definition of “consumer” leaves it unclear whether the framework applies only to persons engaging in a financial transaction with the business to be regulated, to those seeking pre-purchase information, to those seeking general information, or to those who have never interacted with the business to be regulated. As an extreme example, a child who has not yet learned to talk has never engaged in a financial transaction, and so could be excluded from the category “consumer”.

Submission Number: 00221

Received:1/11/2011 6:18:34 AM
Commenter: WiltonDelano
Organization:Design/Build Concepts, Ltd.
State:Virginia
Attachments: 00221-57261.pdf Size: 48 KB
Gentlemen:

I am enclosing attached hereto my comments on the proposed regulation. If it is enacted and would effect our profession, it will be nearly impossible to conform with the local County, Municipal and State laws and regulations as they relate to data required on Zoning applications, Special and conditional use applications and any boundary or subdivision plat that has to go to public record. These all require that the property identification data on all adjoining lots, parcels or tracts be shown on the exhibits which will become public record. In some instances of larger tracts, we will have as many as a hundred or more adjoining lots, many of which have absentee owners. The time and effort to obtain permission for the placement of this data on the required exhibits or plats will cause severe financial loss to the land owner who is making the application. In most cases the interest clock is running and the costs escalate. The failure of one or more of the owners to approve the required use of the data could stop land development in its tracks. The information is on the internet placed by the local counties as a part of the GIS data and courthouse record data which is required by state mandate. The approval of this requirement would cause a possible collapse of the land development processes in Northern Virginia and possibly cause a work stoppage in the surveying, planning and land development engineering firms.

Wilton T. Delano L.S., President
Design/Build Concepts, Ltd.
4160 Dale Boulevard Dale City, Virginia 22193

Submission Number: 00222

Received:1/11/2011 7:25:00 AM
Commenter: BrandonEley
Organization:Kelsey Advertising & Design
State:Georgia
There are already settings on all major browsers regarding the acceptance of cookies and third party (advertiser) cookies. I do not feel that government legislation is needed or warranted as consumers already have the power to restrict access to their information.

As consumers demand more privacy, browsers will integrate features naturally to support their customer base (or win over the customer base of a competitor who does not have such features).

I do not believe it is in the FTC’s best interest to spend time, money and create another law that has to be supported by browser and other software manufacturers. In addition, the information advertisers track in cookies is fairly insignificant (unless a software program is installed).

Submission Number: 00223

Received:1/12/2011 10:44:13 AM
Commenter: PatrickOlson
Organization:Aero-Metric,Inc.
State:Wisconsin
Hello. Our firm is an aerial mapping firm providing geospatial services to federal, state and local clients.I respectfully urge the FTC not to implement any enforcement or broad regulation that would have a harmful affect on firms like mine in the broad private geospatial community.
Specifically, the FTC report imprecisely uses and regulates the term “precise geolocation information” or “precise geolocation data”. This would adversely impact consumers, geospatial firms, and government programs. My firm is particularly concerned that this term was not defined in the FTC staff report and the proposed regulations will have broad and harmful unintended consequences.
The use of the term “geolocation” or other geospatial relevant terminology that appear in the FTC regulations will impose a significant new liability on my firm. It regulates areas of the economy and geospatial activities that have not been identified as a problem or pose any privacy concern to citizens.
The regulations could thwart common, legitimate, and emerging uses of geospatial data for emergency response/post disaster remediation, insurance, environmental protection, E-911 & ambulance services, fleet management broadband mapping, home security, navigation, mortgage foreclosure monitoring/early warning system, and others.
Moreover, activities, technologies, and applications development could be deemed illegal. For example, it would be impractical, if not impossible, for my firm to obtain prior approval or consent from individual citizens prior to acquiring or applying data such as satellite imagery, aerial photography, or parcel, address, or transportation data. The FTC regulation would effectively ban my firm, or our clients, from important value-added, integration and application activities.
Finally, any such FTC regulation could put U.S. companies at a significant and insurmountable competitive disadvantage against foreign firms that may not be covered by that regulation, or for which enforcement would be impractical.
FTC should provide the necessary and desirable privacy protections to individual citizens; however, it should not limit the geospatial community’s ability to grow, prosper, and bring to the market those technologies and applications that meet the economic demands of consumers and citizens.

Submission Number: 00224

Received:1/12/2011 11:09:38 AM
Commenter: Katherine McGinnis
State:North Carolina
I very much support the FTC Staff Report on “Protecting Consumer Privacy in an Era of Rapid Change: A Proposed Framework for Businesses and Policymakers.”

I would like not tracking to be the default. I would like internet businesses to state that they will not keep information each time I have a transaction. Consumers need that level of reassurance.

I also do not want cookies embedded in my computer that will lead to advertisements. If I want something, I’ll look for it. If someone sends me an ad, I won’t buy from them, but they don’t know that.

As a citizen (and a consumer when I want to be), I want to regain control of my online identify and history.

Thank you again for your efforts in this regard. My tax dollars are at work on my behalf!

Sincerely,
Katherine McGinnis

Submission Number: 00225

Received:1/12/2011 11:49:30 AM
Commenter: ThomasHardin
Organization:Southern Engineering & Surveying, Inc.
State:Georgia
It appears to us at this firm that the language of this regulation is too broad, especially as it pertains to the term “precise geolocation data.” While this phrase is used it is not defined. That leaves the term open to wide interpretation which could be used against any and/or all agencies, business, or firms that employ such data. Also the regulation requires any geospatial firm to get “affirmative express consent” from every citizen about whom precise geolocation data is to be collected. That is an impractical to the point of being impossible. This regulation needs to be rewritten to remove the term(s) “precise geolocation data.” After all, at least in Georgia, this data is already a matter of public record. All one has to do is to go to the local tax commissioner’s office, and look it up.

Submission Number: 00226

Received:1/15/2011 6:31:18 PM
Commenter: JohnBates
Organization:Infinite Wellness Solutions
State:North Carolina
As an internet marketer I am firmly opposed to behavioral tracking and believe that the public should be given a way to opt out of all cookies and behavioral tracking.

Too few people understand the risks associated with this type of tracking. Let’s help make it easier for consumers to protect their privacy and create a simple way to opt out of all cookies and tracking of this type.

Submission Number: 00227

Received:1/15/2011 8:28:08 PM
Commenter: Wheeler
State:Utah
I am a web professional and understand the value of the browsing history of users. However, I think it is irresponsible to use this information without consent or knowledge from the user. As is the case with many popular websites users are lurred into the sites with the promise of usefulness, only to find out that their every move is being tracked. When I search for “Gucci Shoes” on Google or say I like “Gucci” on my Facebook profile that information is for me and shouldn’t be stored in a database so that I can be bombarded with shoe ads. While, it may seem harmless for a person to know that I like a particular brand the bigger question is what other information of mine are these sites using to profit from? I find it especially troubling that it isn’t until now that people are starting to stand up and say that this isn’t ok. The trouble with so many technology innovators is that they are more concerned with whether or not they can do something instead of asking if it should be done. Any talented marketing professional will be able to continue to place ads and generate buzz online without my browsing history.

Submission Number: 00228

Received:1/16/2011 9:50:16 AM
Commenter: R.Duffy
State:Connecticut
Re: “Do Not Track” Web Browsers

I fully support the Do Not Track Web Browsers . I urge the FTC to move aggressively on this matter.

The American public is losing too much of its privacy as it is.
I the effort is successful, I think it will also put other privacy invaders on notice that they could next.
Thanks
R. Duffy

Submission Number: 00229

Received:1/17/2011 10:30:12 AM
Commenter: MaggieWolfe Riley
State:California
Dear FTC:

I would really like a simplified OPT-OUT for junk mail of all types – it is a horrible waste of resources, energy, paper/trees, etc, for so much junk mail to be delivered uninvited to so many unwilling and uninterested postal customers. It is beyond annoyance, though it is certainly that. As a US Government operation, I don’t feel it’s right that the USPS is involved in helping pass out junk mail, or making it so easy for “snail-mail spamming” – which is definitely what those “occupant” or “resident” items are! If my internet service provider took money from businesses and then delivered spam that I couldn’t easily opt out of to my email inbox, I’d switch ISPs. We can’t switch postal carriers. This is a monopoly, run by the government, helping companies to spam its customers without options to opt-out or leave.

Please consider the impact to our environment, energy resources, and patience, and give us a simplified opt-out for junk mail.

Submission Number: 00231

Received:1/18/2011 3:07:46 AM
Commenter: MadolynOrr
Organization:n/a
State:California
Attachments: 00231-57343.pdf Size: 339 KB
Thank you very much for proposing regulation of the collection of consumer data online that may actually serve the interests of consumers.
As my attached research paper, “Foxes Guarding the Henhouse: An Assessment of Current Self-Regulatory Approaches to Protecting Consumer Privacy Interests in Online Behavioral Advertising,” describes, the voluntary programs proposed by the FTC in February 2009 and by the online advertising industry in July 2009 (“Self-Regulatory Prinicples in Online Behavioral Advertising”) are totally insufficient to protect the privacy of citizen-consumers.
I appreciate your efforts to improve upon the self-regulatory model, particularly the proposal for standardized privacy notices (or partially standardized notices) which might provide consumers with some ability to understand exactly what data collectors collect and what they do with the information they collect, so that citizen-consumers may usefully (and quickly) compare and contrast the privacy policies of various websites so as to determine whether they wish to provide or protect their personal information.

Submission Number: 00232

Received:1/18/2011 11:10:21 AM
Commenter: RayKingman
Organization:Semcasting
State:Massachusetts
Attachments: 00232-57353.pdf Size: 213 KB DoC: Comments on Building a Privacy Friendly Data Policy.pdf
Creating a Frivacy Friendly Data Policy (attached)

Submission Number: 00233

Received:1/18/2011 4:49:31 PM
Commenter: RossSchulman
Organization:Computer and Communications Industry Association
State:District of Columbia
Attachments: 00233-57368.pdf Size: 38 KB
Please see attached request for an extension of the comment period on the Preliminary Staff Report.

Sincerely,
Ross Schulman
Public Policy and Regulatory Counsel
Computer and Communications Industry Association

Submission Number: 00234

Received:1/19/2011 1:23:54 PM
Commenter: CatherineTucker
Organization:MIT
State:Massachusetts
Attachments: 00234-57398.pdf Size: 139 KB DoC: NTIA_comments_2011_01_24.pdf

 

Submission Number: 00235

Received:1/21/2011 1:26:57 PM
Commenter: Brazil
State:California
Cookies make the consumers life easier. Keep cookies!!

Submission Number: 00236

Received:1/21/2011 1:34:23 PM
Commenter: MarkRuss
State:California
I strongly support the implementation of a “Do Not Track” mechanism.

I am concerned about my privacy and currently use various cumbersome ways to prevent or limit tracking and compiling of personal profiles by advertising, research and other data-collecting companies. This includes managing cookie blacklists via plug-ins, changing browser setting to delete cookies on closing, and manually deleting cookies, esp. Flash cookies which are stored outside of the browser. I would love to have an easier way to accomplish this.

Also, I do not buy the argument of the ad industry that the current form of unsolicited tracking is necessary to improve user experience. For example the practice of retargeting across different sites has little appeal to me as the end user and only makes me feel like I am given the hard-sell to buy things I don’t really need. Even if this approach may occasionally succeed in persuading some people to purchase things, it is questionable who derives the greater benefit from it. I’d argue it’s not the user who is probably just as well off buying an easy-to-find alternative (or perhaps even not buying at all).

Finally, the ad industry claims the profiles they compile are not personally identifiable, but with the rise of particularly Facebook, which is integrated into almost every commercial 3rd-party site via widgets, Like buttons etc., it is easy to link a browser profile to a Facebook ID and hence to a specific personal identity.

I would like to prevent this unless I specifically opt in to such practices.

Submission Number: 00239

Received:1/21/2011 3:55:27 PM
Commenter: AnnCavoukian, Ph.d.
Organization:Office of the Information and Privacy Commissioner of Ontario
State:Outside the United States
Attachments: 00239-57438.pdf Size: 120 KB
00239-57439.pdf Size: 156 KB DoC: Information and Privacy Commissioner of Ontario (Canada) | Dr. Ann Cavoukian, Information and Privacy Commissioner of Ontario
Please find attached a cover letter and submission from Dr. Ann Cavoukian, Information and Privacy Commissioner of Ontario.

Submission Number: 00240

Received:1/22/2011 8:14:02 PM
Commenter: HeidiJacobson
Organization:N/A
State:Wisconsin
The Federal Trade Commission (FTC) aims to construct parity between privacy interests of the people with cutting-edge change, which only the people’s consumer information can relieve for the development of “beneficial new products and services.”

There will always be a ‘catching up,’ as consumer information in this data-driven age is never private. By law, perhaps, yes. Nevertheless, the availability of anything from a driver’s license, an IP address, a credit card here, a social security number there, to even a ‘new’ social security number after some distressed case of id theft–the information is always in the background, in some database; within computers somewhere within the boundaries of that world we live in.

“The proposed report also suggests implementation of a “Do Not Track” mechanism – likely a persistent setting on consumers’ browsers – so consumers can choose whether to allow the collection of data regarding their online searching and browsing activities.”

This sounds nice, as people stay feeling safe. However, if one feels safe and knows to feel safe, there should be more so importance for a framework on a balance of education for ‘defense.’ How does one keep oneself knowledgeable about what to do in certain contexts, and what not to do in other contexts? Example, just this past week I received a voicemail from a person who shall remain nameless, claiming to be from a government agency with whom I have been working somewhat closely with for the past year on a case lasting over four years or so. I was to call this person back. Never have I heard of the name, nor recognized the telephone number, but was quite concerned about the location from which the call came from.

I knew right away what to do when I made the call back. However, this person eventually called me first, before I could return their message. “Hi this is blah blah blah from the blah blah blah blah and –. I am here today with Ms. Blah blah–.” Immediately, as it is my right to do so and every American’s right to do so let this person know: “Yes, I would be absolutely thrilled to answer any of your questions. They should pertain to this matter. If you could please just send me a letter in the mail, on letterhead from the [blah blah blah] with your name, contact information, all of your credentials, and any questions, etc.”

The person seemed not to hear me. The person kept talking, at the same time attempting to keep me on the line. I repeated myself about three times, enters a third person on the line of whom I was supposed to have known. I repeat myself one last time. I hear a dial tone.

Quite obviously, these people were people not working for the governmental agency I have been working with and recently inquiring information from. In fact, likely they were not even from the ‘opposing side,’ if you will. Point being, the people, as the consumers who hold the information, have rights. We have rights and we have privileges. What concerns me here as I write is that too far too many people (and I am not speaking strictly children or the elderly or even disabled) do not even know the difference between a right and a privilege Let alone know what their very rights and privileges are!

Knowingly above sounding Criminal Justice 101 trite, this is a quandary of Wile E. Coyote and Road Runner-the chase will always go on, and both will continue to exist. We can create frameworks full of ‘absurd contraptions and elaborate plans [in pursuit of our] quarry.’ Deborah Meier, deemed an innovator in American education, has an interesting quote—I this interesting: “What I wanted was to create thoughtful citizens — people who believed they could live interesting lives and be productive and socially useful.”

How to separate knowledge and awareness from business and politics is something I do not have an answer to. Perhaps we should stop learning at our ‘Master’s.’ PhD.s are getting us too giddy for information we do not need. Just thinking.

Submission Number: 00241

Received:1/23/2011 12:36:40 PM
Commenter: JohnLuke
State:New Jersey
Customers of commercial web sites like Facebook or other web sites which may use personal information to sell to third parties for revenues as opposed to standard advertising revenues should be provided an easy to read and understand online insturction set from the FTC directly which includes basic information all consumers need to know such as how to omit information not required by the commercial website like Facebook does not require a person to enter their home address or telephone number for participation. Also, this informational resource should provide ways to contact the FTC, the FCC or the FBI in regards to filing complaints about personal solicitations when they are suspected and on standard policies on how these privacy disputes will be regulated and resolved in the future. I agree that these private web sites need to provide easy to understand bold instructions instead of small print long disclosures and these commercial web sites should provide easy to understand ways to omit information they don’t require and how exactly they intend to use specific information which is personally identifyable. I do not agree that all internet usage should not be tracked, rather customers should be provided a way to opt in to being tracked and a way to ensure they may be by default opted out of commercial tracking of internet usage.

Submission Number: 00242

Received:1/23/2011 3:19:37 PM
Commenter: roberts
State:North Carolina
Companies with which I do business now (insurance, banks, credit cards) mail me a “Choice card”- so that I may opt out of receving varios offers by mail,phone, and computer. I am thus given a “Choice”.

When I use my computer I am not given this Choice- I am followed by unknown sources. This is wrong, invasive, and contrary to any privacy issues with which I subscribe.

I am wholly against tracking and wish my voice to be counted. Thank you.

Submission Number: 00245

Received:1/25/2011 7:17:56 PM
Commenter: JohnBurell
State:Alabama

I am in favor of a do not track option. I would hope that this option would be available for all types of internet communication, (smartphone’s, PC’s, Tablet’s or other future devices)or access vehicles ( DSL, Cable, Satellite, WiFI, etc.)

Submission Number: 00246

Received:1/26/2011 2:55:39 PM
Commenter: BrianHuseman
Organization:Intel Corporation
State:District of Columbia
Attachments: 00246-57451.pdf Size: 15965 KB DoC: Intel Corp Dept Commerce green paper comment.pdf

 

Submission Number: 00247

Received:1/26/2011 10:27:54 PM
Commenter: Thomas
State:California
No one has the right to track me. Not advertisers, not Google, not the government. I would like the ability to turn off the ability of anyone to track me. If there are trade-offs in terms of access to information or websites or content, I will choose whether they are worth it, NOT advertisers, Google, the government, or anyone else. I believe this is a basic right all human beings should have. Thanks for the opportunity to comment.

Submission Number: 00248

Received:1/27/2011 12:16:30 AM
Commenter: Smith
State:Massachusetts
Are there practical considerations that support excluding certain types of companies or businesses from the framework – for example, businesses that collect, maintain, or use a limited amount of non-sensitive consumer data?
– I don’t believe there is any legitimate reason to collect or use data, sensitive or non-sensitive, without the individual’s consent.

Is it feasible for the framework to apply to data that can be “reasonably linked to a specific consumer, computer, or other device”?
– Absolutely. Data is already being linked to consumers and their computers or any other device with Internet access.

How should the framework apply to data that, while not currently considered “linkable,” may become so in the future?
– There are a few ways to approach this issue.
+ With the incorporation of the Do Not Track system, any data that is later found to be linked to a consumer, computer, or other device that has already been opted into the Do Not Track system can be disposed of as soon as this linkage is determined.
+ An option for reasonable auditing of tracking data on consumer demand, similar to the legislating compelling free disclosure of credit report information from credit bureaus. This after all is data that is already being aggregated and sold to other companies, or used internally; providing this data to the target consumer will not be burdensome.
+ An option must be developed to allow consumer back tracing of tracked information. At any point that a consumer is presented with individualized advertising, solicitations, or any similar use of data, a company should be obliged to, upon demand, disclose the data used, the company source of that data, and time and date of purchase or aggregation such that a consumer should be able to with reasonable ease track backwards from a use of individual data to the time, place, and means by which that data was collected.

Can companies minimize or otherwise modify the data maintained in legacy data systems to protect consumer privacy interests?
– Companies should be afforded a “safe harbor” in such circumstances. Under such a safe harbor, companies can take specific, documentable, and pre-defined steps to protect consumer privacy interests that will allow them to avoid liability for good-faith efforts. This safe harbor should include standards for data and metadata deletion, and restrict or eliminate online, near-line, and offline access.

Even if first-party marketing in general may be a commonly accepted practice, should consumers be given a choice before sensitive data is used for such marketing?
– Yes. Giving this choice to consumers will promote consumer education as to marketing use of sensitive data.

Should marketing to consumers by commonly-branded affiliates be considered first-party marketing?
– No. Such an approach would encourage greater scope of common branding simply to maximize marketing data flexibility, at the expense of consumer privacy.

How should a universal mechanism be designed for consumers to control online behavioral advertising? How can such a mechanism be offered to consumers and publicized? How can such a mechanism be designed to be clear, easy-to-find, usable, and understandable to consumers?
– A prominent link to an FTC entry point for the Do Not Track database should be visible in the top left corner of every page subject to the DNT requirement. It should be accessible with the most rudimentary browsing applications, and should never be covered by any pop-up advertising. In other words, it should be a prominent, clear, briefly-worded or branded hyperlink.

How can such a mechanism be designed so that it is clear to consumers what they are choosing and what the limitations of the choice are?
– Likely abuse of the link should be anticipated. Brief, easy-to-read text helping consumers to distinguish between the DNT system and maliciously-intended impostor sites should be easily and clearly accessible. URL choice should be made with this concern in mind, and easily accessible verification tools (such as IP tracing) should be provided so that consumers can trust the authenticity of the DNT mechanism.

Submission Number: 00249

Received:1/27/2011 9:57:55 AM
Commenter: ChristopherGraham
Organization:Information Commissioner’s Office UK
State:Outside the United States
Attachments: 00249-57452.pdf Size: 130 KB
Dear FTC

Please find attached the Information Commissioner’s comments on the preliminary staff report ‘Protecting Consumer Privacy in an Era of Rapid Change: A Proposed Framework for Businesses and Policymakers’.

Submission Number: 00250

Received:1/27/2011 11:02:28 AM
Commenter: PhyllisMcMillian
State:Alabama
I do not want to be solicited.

Submission Number: 00251

Received:1/27/2011 11:02:33 AM
Commenter: PhyllisMcMillian
State:Alabama
I do not want to be solicited.

Submission Number: 00252

Received:1/27/2011 1:07:33 PM
Commenter: MaryKennedy
State:Texas
PLEASE! Consumers need and deserve the right to a “do not track” option on the internet, similar to the “do not call list”.

Submission Number: 00253

Received:1/28/2011 7:32:31 AM
Commenter: BradMintun
State:Alabama
Privacy is a right of all citizens, 3rd parties should not be allowed to track activities of private persons in the pursuit of financial gain.

Submission Number: 00254

Received:1/28/2011 10:49:09 AM
Commenter: Rubow
State:Wisconsin
FTC Privacy Framework-Do Not Track

No doubt, those who sell for a living will lobby that all forms of direct marketing to potential customers is a highly valued service to them. Let the customer decide. The default standard should be absolute privacy for ALL information. Let the customer decide to opt in to share personal information or pooled information that may become linked to personal in the future. If, indeed, the consumer does find that being bombarded with advertising is a benefit, they will opt in. There is no need for a thousand pages of exceptions and deference to powerful lobby groups. There should be graded options for privacy rather than just the “take it or leave it” option. The standards should apply to all forms of communication as there is no consumer-based reason to treat smart phones differently from computer-based transactions. Individuals should have the right to browse for information in private. Merely consenting to purchase a product should not give the seller a divine right to hound the buyer forever or sell the option to others to do the same. This does not have to be as complicated as indicated by the many pages of questions to consider. The primary stakeholder is and should be the individual.

Submission Number: 00255

Received:1/28/2011 5:32:09 PM
Commenter: DanielRockey
Organization:Bullivant Houser Bailey PC
State:California
Attachments: 00255-57516.pdf Size: 83 KB
Please accept, as comment on the proposed framework, and in particular on the Do Not Track aspect of the proposal, an article I drafted for inclusion in BNA’s E-Commerce Law & Report. Thank you.

Submission Number: 00256

Received:1/30/2011 5:32:49 AM
Commenter: Stephen Kaylor
State:Alabama
Remove me due to my status as a Police Officer. I would like no information regarding myself and my wife for obvious security reasons.

Submission Number: 00257

Received:1/30/2011 8:52:21 AM
Commenter: JustinCeneviva
State:Connecticut
* Is it feasible for the framework to apply to data that can be “reasonably linked to a specific consumer, computer, or other device”?
o Yes, it is entirely feasible, because data is already being linked to specific consumers, computers, or other devices.
* How should the framework apply to data that, while not currently considered “linkable,” may become so in the future?
o Three approaches can be used.
+ 1. With the incorporation of the Do Not Track system, any data that is later found to be linked to a consumer, computer, or other device that has already been opted into the Do Not Track system can be disposed of as soon as this linkage is determined.
+ 1. An option for reasonable auditing of tracking data on consumer demand, similar to the legislating compelling free disclosure of credit report information from credit bureaus. This after all is data that is already being aggregated and sold to other companies, or used internally; providing this data to the target consumer will not be burdensome.
+ 3. An option must be developed to allow consumer back tracing of tracked information. At any point that a consumer is presented with individualized advertising, solicitations, or any similar use of data, a company should be obliged to, upon demand, disclose the data used, the company source of that data, and time and date of purchase or aggregation such that a consumer should be able to with reasonable ease track backwards from a use of individual data to the time, place, and means by which that data was collected.
* Can companies minimize or otherwise modify the data maintained in legacy data systems to protect consumer privacy interests?
o Companies should be afforded a “safe harbor” in such circumstances. Under such a safe harbor, companies can take specific, documentable, and pre-defined steps to protect consumer privacy interests that will allow them to avoid liability for good-faith efforts. This safe harbor should include standards for data and metadata deletion, and restrict or eliminate online, near-line, and offline access.
* Even if first-party marketing in general may be a commonly accepted practice, should consumers be given a choice before sensitive data is used for such marketing?
o Yes. Giving this choice to consumers will promote consumer education as to marketing use of sensitive data.
* Should marketing to consumers by commonly-branded affiliates be considered first-party marketing?
o No. Such an approach would encourage greater scope of common branding simply to maximize marketing data flexibility, at the expense of consumer privacy.
* How should a universal mechanism be designed for consumers to control online behavioral advertising? How can such a mechanism be offered to consumers and publicized? How can such a mechanism be designed to be clear, easy-to-find, usable, and understandable to consumers?
o A prominent link to an FTC entry point for the Do Not Track database should be visible in the top left corner of every page subject to the DNT requirement. It should be accessible with the most rudimentary browsing applications, and should never be covered by any pop-up advertising. In other words, it should be a prominent, clear, briefly-worded or branded hyperlink.
* How can such a mechanism be designed so that it is clear to consumers what they are choosing and what the limitations of the choice are?
o Likely abuse of the link should be anticipated. Brief, easy-to-read text helping consumers to distinguish between the DNT system and maliciously-intended impostor sites should be easily and clearly accessible. URL choice should be made with this concern in mind, and easily accessible verification tools (such as IP tracing) should be provided so that consumers can trust the authenticity of the DNT mechanism.

Submission Number: 00258

Received:1/30/2011 12:30:12 PM
Commenter: MisterJohnson
Organization:RLM
State:Minnesota
I would like to thank the Federal Trade Commission for acknowledging the criminal activity perpetrated by advertising agencies coast to coast. Clear and concise laws need to be implemented that guarantee consumer protection from unsolicited third part surveillance, via cookies, or any known or future electronic means. A government agency would most likely need court approval to garner the same amount of information that advertisers “steal” on a regular basis. It would be an enormous stride to extend an individuals right to privacy to include third party information caches. To do anything less would be to admit that the Federal Government of the United States of America willfully uses these third parties (email servers, google, aol, etc.) to effectually spy on the public. This is a gross abuse of power, and the American People, those who expect to be protected by the government it elects, will no longer stand for it.

Thank you for your time.

Submission Number: 00260

Received:1/30/2011 2:28:24 PM
Commenter: ZacharyStauber
State:New Mexico
I have been a mapping professional for nearly 15 years now working on everything from public litigation to classified defense department mapping, and I believe that the FTC’s new proposal to protect certain consumer information is good and necessary, and I do not think it should be diluted with exclusions in response to industry lobbying groups like MAPPS who bring up the threat of its having a chilling effect on business and trade.

HIPAA mandates all health information be protected already, troops in combat areas need their personal details (including GPS-enabled cell phone coordinates) protected for obvious reasons, computer illiterate people on social networking sites need better a clearer way to opt-out of having their physical locations and personal details given out to anyone who wants to purchase them. The list goes on.

Perhaps it will make it more difficult to take advantage of people who don’t realize their information is out there, but clever businesses will still find legitimate ways to make money with new GPS-enabled technologies and remaining consumer information while the new FTC rules would protect all consumers.

Submission Number: 00261

Received:1/31/2011 7:36:04 AM
Commenter: TaraDeNucci
State:New York
* Is it feasible for the framework to apply to data that can be “reasonably linked to a specific consumer, computer, or other device”?
o Yes, it is entirely feasible, because data is already being linked to specific consumers, computers, or other devices.
* How should the framework apply to data that, while not currently considered “linkable,” may become so in the future?
o Three approaches can be used.
+ 1. With the incorporation of the Do Not Track system, any data that is later found to be linked to a consumer, computer, or other device that has already been opted into the Do Not Track system can be disposed of as soon as this linkage is determined.
+ 1. An option for reasonable auditing of tracking data on consumer demand, similar to the legislating compelling free disclosure of credit report information from credit bureaus. This after all is data that is already being aggregated and sold to other companies, or used internally; providing this data to the target consumer will not be burdensome.
+ 3. An option must be developed to allow consumer back tracing of tracked information. At any point that a consumer is presented with individualized advertising, solicitations, or any similar use of data, a company should be obliged to, upon demand, disclose the data used, the company source of that data, and time and date of purchase or aggregation such that a consumer should be able to with reasonable ease track backwards from a use of individual data to the time, place, and means by which that data was collected.
* Can companies minimize or otherwise modify the data maintained in legacy data systems to protect consumer privacy interests?
o Companies should be afforded a “safe harbor” in such circumstances. Under such a safe harbor, companies can take specific, documentable, and pre-defined steps to protect consumer privacy interests that will allow them to avoid liability for good-faith efforts. This safe harbor should include standards for data and metadata deletion, and restrict or eliminate online, near-line, and offline access.
* Even if first-party marketing in general may be a commonly accepted practice, should consumers be given a choice before sensitive data is used for such marketing?
o Yes. Giving this choice to consumers will promote consumer education as to marketing use of sensitive data.
* Should marketing to consumers by commonly-branded affiliates be considered first-party marketing?
o No. Such an approach would encourage greater scope of common branding simply to maximize marketing data flexibility, at the expense of consumer privacy.
* How should a universal mechanism be designed for consumers to control online behavioral advertising? How can such a mechanism be offered to consumers and publicized? How can such a mechanism be designed to be clear, easy-to-find, usable, and understandable to consumers?
o A prominent link to an FTC entry point for the Do Not Track database should be visible in the top left corner of every page subject to the DNT requirement. It should be accessible with the most rudimentary browsing applications, and should never be covered by any pop-up advertising. In other words, it should be a prominent, clear, briefly-worded or branded hyperlink.
* How can such a mechanism be designed so that it is clear to consumers what they are choosing and what the limitations of the choice are?
o Likely abuse of the link should be anticipated. Brief, easy-to-read text helping consumers to distinguish between the DNT system and maliciously-intended impostor sites should be easily and clearly accessible. URL choice should be made with this concern in mind, and easily accessible verification tools (such as IP tracing) should be provided so that consumers can trust the authenticity of the DNT mechanism.

Submission Number: 00262

Received:1/31/2011 8:44:08 AM
Commenter: PamelaStewart
State:Virginia
I am in agreement with your impression that the Direct Marketing industry fails to self-regulate when it comes to consumer tracking, etc. I feel it is a personal violation for marketers to collect data on me while I am making purchases or exploring options. I see it as comparable to having a private investigator follow me from store to store in a brick-and-mortor environment. History demostrates, over and over, that commercial enterprises have only one driving force – to make money. Self-regulating is contrary to that goal and industry fails until forced to do so. Online marketers and servers would argue that consumers should opt out site by site – why should the online industry enjoy that option when telemarketers and direct mailers don’t [DO NOT MAIL and DO NOT CALL lists are industry-wide.] I would also note that online marketers have not done an adequate job of disclosing to consumers their tracking practices – I’ve not seen a single etailer that has a comprehensive disclosure statement regarding their policies and procedures. They rely on consumer ignorance. I strongly support the FCC in limiting the stealth practices currently employed by onliners.

Submission Number: 00263

Received:1/31/2011 9:36:48 AM
Commenter: GarthLawrence
Organization:The Haruspex Group
State:Colorado
Having worked in the Geospatial profession for more than 35 years I feel it important to comment on the various efforts under way in the Federal government to create new “privacy” protections for citizens. These proposed rules apply to the collection, storage and use of certain data about individuals, including their address

The rules use the term “precise geolocation data” and prevent any private firm from collecting, storing or using such data without the citizen’s advance approval. This is an impractical and impossible requirement for private geo spatial firms.

The Federal proposals are poorly written, do not define precise geolocation data, and have serious unintended consequences for industries and professions beyond those these Federal authorities are attempting to regulate.

I understand that the geospatial industry association, MAPPS, has submitted comments to the FTC and Commerce Department opposing regulatory language that would limit the collection, sharing or use of “precise geolocation data”.

I fully support the MAPPS effort.

Submission Number: 00264

Received:1/31/2011 1:53:30 PM
Commenter: BryanMelmed
Organization:springbok media
State:Connecticut
There seem to be three basic arguments against ensuring consumer privacy.

The weakest is that consumers appreciate targeted advertising. If it were true, I doubt the benefit would justify the cost, and if I am wrong, consumers still have the option to enable personalization.

A second is that privacy laws will impose economic ruin. This is a speculative argument invoked by industry at every turn. Media has thrived without behavioral tracking; there is no reason to believe it is suddenly essential. More importantly, without a privacy framework we create incentives for further intrusion. Networks compete on how clearly they can observe user behavior, the only limitation being how sophisticated tracking technology has become. This limitation is fast evaporating.

The third argument is that privacy laws are unnecessary because the risk is manageable. And yet, just this year, thousands of people will struggle to recover from identity theft. Data is vulnerable even in the most responsible hands. No matter what is promised by way of self-regulation, having your personal details encoded, digitized, and shared across multiple parties is inherently dangerous.

We are racing to disaster with the certainty of the Titanic. It is time to change course.

Submission Number: 00265

Received:1/31/2011 3:08:40 PM
Commenter: MelissaMacGregor
Organization:SIFMA
State:District of Columbia
Attachments: 00265-57539.pdf Size: 291 KB DoC: SIFMA Comment Letter – Commerce FTC – 1-31-11.pdf
Please see the attached comment letter.

Submission Number: 00266

Received:1/31/2011 3:20:48 PM
Commenter: AmyMann
State:Washington
I am inundated with too many solicitations – via mail, phone and now electronically. I am in favor of limiting the opportunities for businesses and other organizations to track my “preferences” and then use them to try to sell me products and services. I browse the internet for information but that doesn’t mean that I am interested in buying everything I see. Window shopping should still be allowed – I can walk by a store window and look at what is on display without having someone run out the door to try to make a sale. Why should using the internet be any different?

If folks want to voluntarily give up their personal information to various organizations that is there privilege but it should be a choice. It should be a choice that we get to OPT IN to. Not one we have to opt out of.

If businesses and other organizations (non-profits are just as guilty of invading private space) complain that it is ruining their business model, perhaps there is something wrong with their models. :-)

Thank you for working on this issue.

Submission Number: 00267

Received:1/31/2011 9:14:41 PM
Commenter: PhilippeCoueignoux
Organization:ePrio
State:Massachusetts
Attachments: 00267-57550.pdf Size: 365 KB DoC: ePrio-Comments-to-the-DoC-on-Privacy.pdf
Dear Sir or Madam,

please find here attached in pdf format
my feedback to your consultation on privacy

Respectfully yours

Philippe Coueignoux PhD

Submission Number: 00270

Received:2/1/2011 7:34:33 AM
Commenter: GregoryVarner
State:Alabama
I am requesting confidential treatment that this information not be avialbe for public record.

Submission Number: 00271

Received:2/1/2011 8:24:18 AM
Commenter: Morten HjorthJahnsen
Organization:eNACSO
State:Outside the United States
Attachments: 00271-57554.pdf Size: 1212 KB
Federal Trade Commission
Office of the Secretary
Room H-114
Annex 600 Pennsylvania Avenue NW
Washington DC 20580

Re: FTC Staff Preliminary Report on Protecting Consumer Privacy – File No. P095416

Dear Sir/Madam,
Please see attached the European NGO Alliance for Child Safety Online’s (eNACSO) comments on the FTC Staff Preliminary Report on Protecting Consumer Privacy – File No. P095416

Submission Number: 00272

Received:2/1/2011 1:31:16 PM
Commenter: JoanneTravis
Organization:American Bar Association
State:Illinois
Attachments: 00272-57555.pdf Size: 366 KB
The ABA Section of Antitrust Law is pleased to submit the attached comments in response to the FTC’s preliminary staff report, Protecting Consumer Privacy in an Era of Rapid Change: A Proposed Framework for Businessnes and Policymakers.

If you have any questions, please do not hesitate to let us know.

Submission Number: 00273

Received:January 28, 2011
Commenter: Reed D.Taussig
Organization:ThreatMetrix Inc.
State:California
Attachments: 00273-57557.pdf Size: 679 KB

Submission Number: 00274

Received:2/3/2011 1:37:03 PM
Commenter: JeremyDeane
Organization:Plymouth Rock Assurance
State:Massachusetts
Organizations should think of themselves as stewards of a consumer’s information. In other words, a person’s uniquely identifiable data is on loan to the organization governed under the aegis of an explicit contract clearly agreed upon at the time of the exchange.

Similar to the security principle of least privilege, organizations should by default assume that personally identifiable data should only be used for the purpose at hand and not transferable. The contract can be expanded if at the time of the exchange the consumer explicitly grants an organization permission to further use or transfer his or her data.

Submission Number: 00275

Received:2/3/2011 1:39:15 PM
Commenter: LindaCriddle
Organization:Safe Internet Alliance
State:Virginia
Attachments: 00275-57570.pdf Size: 44 KB
In response to increasing consumer demand, the Federal Trade Commission has recommended the creation of a Do-Not-Track service that would allow consumers to opt out of online data tracking by advertisers. We firmly believe that consumers have the right to decide who can track their actions online, when those actions can be tracked and what information about those actions can be tracked.

However, the question of whether this should be a government regulated function, or an industry driven function is worth considering.

The attached comments from the Safe Internet Alliance address these challenging questions.

Submission Number: 00276

Received:2/3/2011 6:14:41 PM
Commenter: MikeBaker
Organization:DataXu
State:Massachusetts
Attachments: 00276-57571.pdf Size: 62 KB

Submission Number: 00277

Received:2/4/2011 12:30:22 PM
Commenter: John Schumann
State:Ohio
Internet tracking is nothing more than stalking; it’s peeping toms, it is
another form of harassment and surveillance – unwanted and uninvited. Most
states have laws against this type of behavior yet these laws have not yet been
applied to cyberspace. Articles in the Wall Street Journal in the summer of 2010
clearly show how surreptitious, intrusive, and persistent these business have
become. Their “beacons” replicate themselves upon deletion. Yet, most citizens
are unaware that age, gender, race, zip code, income, martial status, health
concerns, hobbies,interests have become public information. The industry’s
response to this is ludicrous. “We don’t track anyone by name.” Correct, no
names, but how many [redacted]? These business have used a
public medium to basically create a permanent surveillance system. The banking
industry has done the same thing by sharing their customer’s transaction
history. If someone is unconcerned about sharing their personal data with the
world, that is fine. Each person should have the right to choose. In today’s
environment, there is no choice. All citizens are raped of their privacy “as
permitted by law” – as the banks tell us every year. Congress has shown that
where “business interest” [read: money] is at stake, the public interest be
damned and no substantive action can be enacted. A Do Not Track option is an
excellent idea. It is long overdue.

Submission Number: 00278

Received:2/7/2011 8:46:21 AM
Commenter: CarolClark
State:Louisiana
I just read the privacy proposal and I am in complete agreement with everthing stated in it. I especially like the idea of having a way to program my computer to protect my privacy. Thank you so much.

Submission Number: 00279

Received:2/8/2011 10:52:07 AM
Commenter: AngelaGleason
Organization:American Insurance Association
State:District of Columbia
Attachments: 00279-57591.pdf Size: 86 KB
Attached are the American Insurance Association’s comments regarding the FTC’s preliminary report entitled “Protecting Consumer Privacy in an Era of Rapid Change.”

Submission Number: 00280

Received:2/8/2011 1:57:35 PM
Commenter: KevinPomfret
Organization:Centre for Spatial Law and Policy
State:Virginia
Attachments: 00280-57592.pdf Size: 276 KB
Please find attached comments of the Centre for Spatial Law and Policy with respect to certain portions of the Preliminary FTC Staff Report on “Protecting Consumer Privacy in an Era of Rapid Change: A Proposed Framework for Businesses and Policymakers”

Submission Number: 00281

Received:2/8/2011 8:13:51 PM
Commenter: BertRankin
Organization:ThreatMetrix Inc.
State:California
Attachments: 00281-57593.pdf Size: 903 KB
Dear Sir or Madam:

Attached is a comment letter regarding the Preliminary FTC Staff Report on Protecting Consumer Privacy in an Era of Rapid Change: A Proposed Framework for Businesses and Policymakers. Thank you for your consideration.

Submission Number: 00282

Received:2/8/2011 10:56:49 PM
Commenter: Vigilante
State:New York
There is a hideous practice by supposed social-networking databases to collect personally identifying information from so-called public records and hold the people to whom the information belongs hostage. The companies behind the databases refuse to delete the posted names and accompanying home addresses, etc., without the victim’s “claiming” the posted identity to be his or her own, and providing even more complete personal information to the companies through an online form that even requires two former residential addresses. What does the company do with this? One can only shudder to contemplate the outcome… This happens to people who have never visited the site, let alone sign up for membership. Such companies are out of control. A coincidental rash of firms that provide privacy for a price, “reputation-restorers,” cropped up as this “public” information posting by these surreptitious database services increased. In addition to posting anyone’s personal information they can get hold of, these same firms have the practice of hijacking personal address books from the computers of those unfortunate, unsuspecting people who actually do sign up with them. All those listed in their address books received e-mail invitations from the poor victimized “sender’s” e-mail address requesting them to join. This is flagrant forgery, and complaints about such firms as MyLife.com (which took over Reunion.com) and FaceBook pervade consumer-complaint message boards. What is the worst that can happen from this? One poster on ConsumerAffairs.com put it very succinctly:

“This company and other[s] like it sell one[‘]s personal information without one[‘]s consent.

This is personal information that can be used for ID Theft, stalkers, rapist[s], etc. I’ve requested various times for them to remove my information but they hide behind ‘it’s public information.’
They should be legally forced to disclose where they get this public information upon request.

People should get together to…file a class action lawsuit to permanently delete one[‘]s personal information and disclose where they get everyone’s information.”

–Nick of Los Angeles, CA Dec. 30, 2010

The situation is an epidemic. Without privacy protection and restrictions on the Internet, there is no point in citizens who don’t pay ransom subscriptions to privacy-protecting firms are helpless online, and shouldn’t even bother using the World Wide Web. At the least, they should do what I have resigned to do with every online excursion that requires my inputting information in any electronic form field, from here on–that is, to absolutely withhold my real ID.

Please protect the citizens of the United States by instituting measures that will end our irrevocable victimization by these unconscionable exploiters who don’t deserve the air they breathe, let alone the bandwidth their databases occupy, and least of all, the money they get for selling our personal information. Curse them all.

Submission Number: 00283

Received:2/9/2011 6:33:16 PM
Commenter: RussellGlass
Organization:Bizo, inc.
State:California
Attachments: 00283-57596.pdf Size: 107 KB
The FTC’s recommendation for Do Not Track (DNT) functionality has been a great lightning rod for industry action, spurring online retailers and the online advertising industry to think hard about the right way to handle delicate privacy issues. However, there are some significant problems with the direction the industry is taking, requiring further clarification and focus from the FTC. I believe that inaction by the FTC to create a course correction could lead to significant consumer and industry harm, and a stifling of high-tech, small business success and innovation in the US, in addition to further monopolistic conditions for Google and Microsoft.

Detailed comments in attached Word doc.

Thanks,
Russell Glass

Submission Number: 00284

Received:2/10/2011 12:27:09 PM
Commenter: JamesVan Rens
Organization:Riegl USA, Inc
State:Florida
I respectfully urge the FTC not to implement any enforcement or broad regulation that would have a harmful
affect on firms like mine in the broad private geospatial community.
Specifically, the FTC report imprecisely uses and regulates the term “precise geolocation information” or
“precise geolocation data”. This would adversely impact consumers, geospatial firms, and government
programs. My firm is particularly concerned that this term was not defined in the FTC staff report and the
proposed regulations will have broad and harmful unintended consequences.
The use of the term “geolocation” or other geospatial relevant terminology that appear in the FTC regulations
will impose a significant new liability on my firm. It regulates areas of the economy and geospatial activities
that have not been identified as a problem or pose any privacy concern to citizens.
The regulations could thwart common, legitimate, and emerging uses of geospatial data for emergency
response/post disaster remediation, insurance, environmental protection, E-911 & ambulance services, fleet
management broadband mapping, home security, navigation, mortgage foreclosure monitoring/early warning
system, and others.
Moreover, activities, technologies, and applications development could be deemed illegal. For example, it
would be impractical, if not impossible, for my firm to obtain prior approval or consent from individual citizens
prior to acquiring or applying data such as satellite imagery, aerial photography, or parcel, address, or
transportation data. The FTC regulation would effectively ban my firm, or our clients, from important valueadded,
integration and application activities.
Finally, any such FTC regulation could put U.S. companies at a significant and insurmountable competitive
disadvantage against foreign firms that may not be covered by that regulation, or for which enforcement would
be impractical.
FTC should provide the necessary and desirable privacy protections to individual citizens; however, it should
not limit the geospatial community’s ability to grow, prosper, and bring to the market those technologies and
applications that meet the economic demands of consumers and citizens.

Submission Number: 00285

Received:2/10/2011 1:00:34 PM
Commenter: MaryPotter
Organization:Keystone Aerial Surveys, Inc.
State:Pennsylvania
This proposed regulation would stifle my business, which is aerial survey acquisition with unnecessary and burdonsome regulations which have never been required in the past. We have been in the aerial survey profession for over 45 years and it is difficult enough without adding more regulations and complications that would not add to public health or safety and would kill new jobs and business opportunities. It would be impractical, if not impossible, for Keystone to obtain prior approval or consent from individual citizens prior to acquiring or applying data such as aerial photography. This could very well put an end to our business.
Please, just say NO to this regulation.
Sincerely,
Mary Potter
President
Keystone Aerial Surveys, Inc.

Submission Number: 00286

Received:2/10/2011 1:09:05 PM
Commenter: IanWhite
Organization:Urban Mapping Inc
State:California
I respectfully urge the FTC not to implement any enforcement or broad regulation that would have a harmful affect on firms like mine in the broad private geospatial community.

Specifically, the FTC report imprecisely uses and regulates the term “precise geolocation information” or “precise geolocation data”. This would adversely impact consumers, geospatial firms, and government programs. My firm is particularly concerned that this term was not defined in the FTC staff report and the proposed regulations will have broad and harmful unintended consequences.

The use of the term “geolocation” or other geospatial relevant terminology that appear in the FTC regulations will impose a significant new liability on my firm. It regulates areas of the economy and geospatial activities that have not been identified as a problem or pose any privacy concern to citizens.

The regulations could thwart common, legitimate, and emerging uses of geospatial data for emergency response/post disaster remediation, insurance, environmental protection, E-911 & ambulance services, fleet management broadband mapping, home security, navigation, mortgage foreclosure monitoring/early warning system, and others.
Moreover, activities, technologies, and applications development could be deemed illegal. For example, it would be impractical, if not impossible, for my firm to obtain prior approval or consent from individual citizens prior to acquiring or applying data such as satellite imagery, aerial photography, or parcel, address, or transportation data. The FTC regulation would effectively ban my firm, or our clients, from important value- added, integration and application activities.

Finally, any such FTC regulation could put U.S. companies at a significant and insurmountable competitive disadvantage against foreign firms that may not be covered by that regulation, or for which enforcement would be impractical.

FTC should provide the necessary and desirable privacy protections to individual citizens; however, it should not limit the geospatial community’s ability to grow, prosper, and bring to the market those technologies and applications that meet the economic demands of consumers and citizens.

Submission Number: 00287

Received:2/10/2011 1:15:49 PM
Commenter: DevinKelley
Organization:HJW Photo Science
State:California
Points to Make in Comments
I respectfully urge the FTC not to implement any enforcement or broad regulation that would have a harmful
affect on firms like mine in the broad private geospatial community.
Specifically, the FTC report imprecisely uses and regulates the term “precise geolocation information” or
“precise geolocation data”. This would adversely impact consumers, geospatial firms, and government
programs. My firm is particularly concerned that this term was not defined in the FTC staff report and the
proposed regulations will have broad and harmful unintended consequences.
The use of the term “geolocation” or other geospatial relevant terminology that appear in the FTC regulations
will impose a significant new liability on my firm. It regulates areas of the economy and geospatial activities
that have not been identified as a problem or pose any privacy concern to citizens.
The regulations could thwart common, legitimate, and emerging uses of geospatial data for emergency
response/post disaster remediation, insurance, environmental protection, E-911 & ambulance services, fleet
management broadband mapping, home security, navigation, mortgage foreclosure monitoring/early warning
system, and others.
Moreover, activities, technologies, and applications development could be deemed illegal. For example, it
would be impractical, if not impossible, for my firm to obtain prior approval or consent from individual citizens
prior to acquiring or applying data such as satellite imagery, aerial photography, or parcel, address, or
transportation data. The FTC regulation would effectively ban my firm, or our clients, from important valueadded,
integration and application activities.
Finally, any such FTC regulation could put U.S. companies at a significant and insurmountable competitive
disadvantage against foreign firms that may not be covered by that regulation, or for which enforcement would
be impractical.
FTC should provide the necessary and desirable privacy protections to individual citizens; however, it should
not limit the geospatial community’s ability to grow, prosper, and bring to the market those technologies and
applications that meet the economic demands of consumers and citizens.

Submission Number: 00288

Received:2/10/2011 2:31:07 PM
Commenter: Bill Krawietz
Organization:Krawietz Aerial Photo, LLC
State:Texas
Our firm does aerial photography for use in surveying and mapping. If the proposed law passes you will basically put us out of business. More importantly the outfall that the public will feel will not only be economic but endanger the health, safety and welfare of all citizens. The photography we take is used in many ways including drainage, flood mapping, highway and road design engineering, land development, 911 emergency data bases, crop studies, forestry, enviromental and wetland monitoring just to name a few. It would be impossible to get approval of everyone that may have there property appear in the photo. Please consider the far reaching impact to the country if such a law was to pass. It appears on the surface to a great protection of our privacy but there are more negatives than positive aspects to the legislation. I may be contacted if you would like any additional information or comments.

Please consider this example:

We fly photography of a landfill for the landfill company so they can do the required monitoring of the site. They must comply with several regualtions on the height, scope and rainwater runoff of the facility. All of our photography is shot in steroscopic form (ie: 3 deminsional). The photos are viewed in 3D to generate contour maps. The maps are used to make sure the surrounding properties are not adversely effected by the sanitary landfill.

If we were unable to photograph the landfill and surronding property the impact to the nearby homes, schools, churches, businesses would be devastating.

Yes we would be given consent by the owners of the landfill but it would be virtually impossible to secure a release from anyone who could possibly be in the photo.

Another scenario: We are often hired by a governmental agency to fly aerial photography of site for enviromental or taxing entity studies. Property owners of this type do not want the government to know what they are doing behind locked gates. The same goes for the growing of illegal substances such a marijuana. It is much safer to observe from the air before law enforcement raids an area.

As you can see passing this legislation would actually harm citizens, businesses and goverment workers.

I could go on and on about the positive side of aerial photography and its many uses.

Please consider the impact of such legislation.

Thanks,
Bill Kraweitz
Owner, Krawietz Aerial Photography
Mayor of Bulverde, TX

Submission Number: 00289

Received:2/10/2011 3:44:18 PM
Commenter: RonMacke
Organization:Aerial Surveys International,LLC
State:Colorado
As a Company engaged in the GeoSpacial profession, I am deeply concerned about the potential raminifactions to my business from some of the terms in the Dec 1, 2010 FTC report,( Protective Consumer Privacy in an area of rapid change.) In my opinion some of the terminology definations are extremely ambigious and could be construded to suggest that my firm would have to contact all the the property owners before I could perform any Aerial Survey over their property. To give you an example, in the Spring of 2010 we flew an Aerial Survey over the Denver Metropolitan area for the Denver Regional Council of governments. If I would have been required to inform each property owner within the Denver metropolitan area, I would not have been able to perform the Survey. In the case of the BP oil spill, almost instant responce was needed for the aerial imagery survey. In this situtation, contacting property owners would have been impossible.

Submission Number: 00290

Received:2/10/2011 4:03:53 PM
Commenter: MarkSchubert
Organization:Aerial Surveys International
State:Colorado
Background on Comments

On December 1, 2010, the Federal Trade Commission (FTC) issued a preliminary staff report, “Protecting Consumer Privacy in an Era of Rapid Change”, that proposes a framework to balance the privacy interests of consumers with innovation that relies on consumer information to develop beneficial new products and services. The proposed report also suggests implementation of a “Do Not Track” mechanism -likely a persistent setting on consumers’ browsers -so consumers can choose whether to allow the collection of data regarding their online searching and browsing activities. However, the FTC report goes beyond internet tracking.

Comment:

Our firm collects aerial photography for mapping services such as disaster prevention, urban drainage, 911, Light Rail, Beatle kill study, Pipe line survey and much more for the Counties, USDA, USFS, NOAA, FIMA, DOT’s, USGS and many other government and private mapping programs. I respectfully urge the FTC not to implement any enforcement or broad regulation that would have a harmful affect on firms like mine in the broad private geospatial community.

Specifically, the FTC report imprecisely uses and regulates the term “precise geolocation information” or “precise geolocation data”. This would adversely impact consumers, geospatial firms, and government programs. My firm “Aeial Surveys International” in Watkins, CO is particularly concerned that this term was not defined in the FTC staff report and the proposed regulations will have broad and harmful unintended consequences.

The use of the term “geolocation” or other geospatial relevant terminology that appear in the FTC regulations will impose a significant new liability on my firm. It regulates areas of the economy and geospatial activities that have not been identified as a problem or pose any privacy concern to citizens.

The regulations could thwart common, legitimate, and emerging uses of geospatial data for emergency response/post disaster remediation, insurance, environmental protection, E-911 & ambulance services, fleet management broadband mapping, home security, navigation, mortgage foreclosure monitoring/early warning system, and others.

Moreover, activities, technologies, and applications development could be deemed illegal. For example, it would be impractical, if not impossible, for my firm to obtain prior approval or consent from individual citizens prior to acquiring or applying data such as satellite imagery, aerial photography, or parcel, address, or
transportation data. The FTC regulation would effectively ban my firm, or our clients, from important value-added, integration and application activities.

Finally, any such FTC regulation could put U.S. companies at a significant and insurmountable competitive disadvantage against foreign firms that may not be covered by that regulation, or for which enforcement would be impractical.

FTC should provide the necessary and desirable privacy protections to individual citizens; however, it should not limit the geospatial community’s ability to grow, prosper, and bring to the market those technologies and applications that meet the economic demands of consumers and citizens.

Thank you. Mark Schubert

Submission Number: 00291

Received:2/10/2011 8:16:23 PM
Commenter: AnthonyFollett
Organization:AeroMetric, Inc.
State:Alaska
My firm has been providing professional aerial photography and mapping services in Alaska since 1960. Our clients call on us to provide both precision and accuracy in the geospatial services we offer. These two terms have very different meanings and must therefore be clearly defined. The proposed terminology of “precise geolocation information” is vague and open to myriad interpretations.

Of much greater concern than terminology is the notion of severely restricting the services my firm offers to government, academia, industry and the public at large. Our professional geospatial services truly do improve the quality of life for Americans as we are involved in both development and preservation activities. To restrict the legitimate services we offer our nation is to adversely impede the value of our services in promoting responsible development and management of our natural treasures.

Regulations such as those proposed further burden our company with costs and reporting requirements, thereby making us less competitive against global organizations not subject to such regulations.

I respectfully request that FTC not implement any enforcement or broad regulation that would harm my firm, my employees, and the clients we serve. Thank you for your consideration.

Submission Number: 00292

Received:2/11/2011 7:04:22 AM
Commenter: KenFleming
Organization:Coleman Caldwell Co., LLC
State:Kentucky
As a geospatial professional, I strongly urge FTC to not implement any enforcement or general regulation that will have a serious affect on us in the geospatial profession.

The FTC report uses the term “precise geolocation information” or “precise geolocation data” which is not defined and could have broad and harmful unintended consequences. this term would increase our liability and drive costs up which will impact government agencies.

The ramifications of this proposal will impact emergency response, insurance, environmental protection, fleet management broadband mapping, home security, navigation, mortgage foreclosure systems, and many others. In addition, activities, technologies, and applications development could be deemed illegal. For example, it would be impractical, if not impossible, for my firm to obtain prior approval or consent from individual citizens prior to acquiring or applying data such as satellite imagery, aerial photography, or parcel, address, or transportation data. The FTC regulation would effectively ban me, or our clients, from important value- added, integration and application activities.

In a global economy, this regulation would put us at a competitive and insurmountable disadvantage against foreign firms that are not covered by this regulations. I understand FTC should provide necessary and desirable protections to individual citizens; however, it should not limit the geospatial community’s ability to grow, prosper, and bring to the market those technologies and applications that meet the economic demands of consumers and citizens.

Thank you for your consideration

Submission Number: 00293

Received:2/11/2011 11:37:08 AM
Commenter: JohnCopple
Organization:Sanborn Map Company
State:Colorado
I respectfully urge the FTC not to implement any enforcement or broad regulation that would have a harmful and detrimental affect on firms like mine in the broad private geospatial community.
Specifically, the FTC report imprecisely uses and regulates the term “precise geolocation information” or “precise geolocation data”. This would adversely impact consumers, geospatial firms, and government
programs. My firm is particularly concerned that this term was not defined in the FTC staff report and the proposed regulations will have broad and harmful unintended consequences.
The use of the term “geolocation” or other geospatial relevant terminology that appear in the FTC regulations will impose a significant new liability on my firm. It regulates areas of the economy and geospatial activities that have not been identified as a problem or pose any privacy concern to citizens.
The regulations could thwart common, legitimate, and emerging uses of geospatial. For example the data is used today for urban planning,storm water management, agriculture management, broadband mapping, emergency response/post disaster remediation, insurance, environmental protection, E-911 & ambulance services, fleet
management, homeland security, navigation, mortgage foreclosure analysis, fire risk and property management and a myriad of other uses.
Moreover as currently stated the activities, technologies, and applications development related to geospatial could be deemed illegal. For example, it would be impractical, if not impossible, for my firm to obtain prior approval or consent from individual citizens
prior to acquiring or applying data such as satellite imagery, aerial photography, or parcel, address, or
transportation data. The FTC regulation would effectively ban my firm, or our clients (cities,counties, state governments, and native American tribes from realizing the value from geospatial data in important value-added, integration, and application activities my frim performs to provide these customers with information.
Finally, any such FTC regulation could put U.S. companies at a significant and insurmountable competitive
disadvantage against foreign firms that may not be covered by that regulation, or for which enforcement would be impractical.
FTC should provide the necessary and desirable privacy protections to individual citizens; however, it should not limit the geospatial community’s ability to grow, prosper, and bring to the market those technologies and applications that meet the economic demands of consumers and citizens.

Submission Number: 00294

Received:2/11/2011 12:33:56 PM
Commenter: AlanMikuni
Organization:Towill, Inc.
State:California
My company is involved in the acquisition and manipulation of surveying and mapping data, that is, geospatial information. The work of Towill, Inc., and our colleagues in the geospatial community involves collection of aerial and space imagery and mapping information and data over many hundreds, perhaps, thousands of square miles of land surface, which likely encompass the holdings of hundreds, or thousands, perhaps, millions, of American citizens. The nature of Towill’s business is to acquire and process accurate (precise) and reliable geospatial data (geo-location and descriptive information about features on the surface of the Earth), so that our customers and clients will be able to use the information in their day-to-day decision-making processes.

I understand the importance of FTC’s mandate to provide necessary and desirable privacy protections to individual American citizens, but the tenets of your proposed “privacy” rule will impinge on my company’s ability to conduct business. The terminology, “precise geolocation data”, if it is not adequately defined, could be interpreted as exactly what my company acquires and processes. The need to obtain prior approval of citizens in order for firms like mine to acquire “precise geolocation data” about them and their property will pose near-impossible logistical and, likely, expensive challenges. Broad terms like “precise geolocation data” must be precisely defined before regulations like that you are proposing can be implemented. The implications of enactment using a broad-brush and imprecise definition can be a detriment to many sectors of the American economy, most specifically, geospatial firms like Towill, Inc., and other firms represented by the Management Association for Private Photogrammetric Surveyors (MAPPS). I respectfully urge the FTC not to implement an enforcement or broad regulation that would have a harmful affect on firms like mine.

Thank you,
Alan Mikuni, PE CP
Towill, Inc.
a member of MAPPS.

Submission Number: 00295

Received:2/11/2011 3:34:58 PM
Commenter: EdwinHuddleson
State:District of Columbia
This comment is submitted to support the FTC staff’s recommendation for a “Do Not Track” mechanism to allow consumers to opt out of the collection of information about their internet behavior for targeted advertising.

In particular, I wish to respond to the lengthy criticism of this FTC proosal that appears in “Will the FTC’s ‘Do Not Track’ Proposal Spell the End of Free Internet Content,” 79 USLW 2023 (February 23, 2011). The central thesis of the criticism is that internet rules should mirror the rules that apply to the rest of the world; that an “individual’s right to privacy generally ends … when she chooses to venture out where she may be easily observed or overheard, or chooses to disclose information to third parties”; and that

“Few would argue … that an individual who enters a brick
and mortar location should have the legal right to prohibit
the owner from observing them, monitoring their movements
within the building, or offering purchase suggestions.” [79
USLW at 2025]

This criticism is ill-considered.

I respectfully submit that: Few would expect that by entering a brick and mortar store, an individual thereby confers a “right” upon the store owner to pester the individual forever thereafter (after the individual leaves the store) with advertisements and offers sent by mail and email to the individual’s home. Cf. Pineda v. Williams-Sonoma Stores, Inc. (California Supreme Court February 10, 2011) (court holds that retail stores may not request and record a consumer’s zip code as part of a credit card transaction, enforcing Cal.Civil Code s1747.08 that prohibits businesses from retaining cardholders’ “personal identification information” to use for later marketing purposes). See generally Bamberger & Mulligan, Privacy on the Books and on the Ground, 63 Stanford L.Rev. 249 at 283, 301-302 (January 2011) (consumer “push back” has led many companies (e.g., AOL, American Express, Intel, DoubleClick) to scrap internet data mining and marketing schemes that invaded personal privacy).

Three cheers for the FTC’s proposed “Do Not Track” mechansm!

Submission Number: 00296

Received:2/14/2011 9:33:06 AM
Commenter: MarilynZigmund Luke
Organization:America’s Health Insurance Plans
State:District of Columbia
Attachments: 00296-57614.pdf Size: 77 KB DoC: privacynoi2010 FINAL.pdf
America’s Health Insurance Plans (AHIP)

Submission Number: 00297

Received:2/14/2011 11:05:21 AM
Commenter: RobertSprague
Organization:University of Wyoming
State:Wyoming
Attachments: 00297-57615.pdf Size: 60 KB

Submission Number: 00298

Received:2/15/2011 12:57:23 PM
Commenter:
Organization:CNIL
State:
Attachments: 00298-57628.pdf Size: 58 KB

Submission Number: 00299

Received:2/15/2011 4:10:38 PM
Commenter: CraigSpiezle
Organization:Online Trust Alliance (OTA)
State:Washington
Attachments: 00299-57622.pdf Size: 367 KB    DoC: Commerce Dept Response_final.pdf
Donald S. Clark, Secretary
Federal Trade Commission
Office of the Secretary
Room H-113 (Annex W)
600 Pennsylvania Ave., N.W.
Washington, D.C. 20580

RE: FTC Staff Preliminary Report on Protecting Consumer Privacy – File No. P095416

Dear Mr. Clark,

Thank you for providing the Online Trust Alliance (OTA) the opportunity to submit comments to the draft report. As a member-based entity with over 80 organizations representing the internet ecosystem, OTA’s mission is to develop and advocate best practices to mitigate privacy, identity, and security threats to online services, brands, organizations and consumers. Through our combined efforts our goal is to enhance online trust and confidence, business innovation and ultimately the vitality of online commerce.

OTA commends the Federal Trade Commission on this preliminary report. We believe this report will make an important contribution to advance best practices, protect consumers, spur innovation and enhance online trust. Efforts to support the evolving role and importance of privacy protections and self-regulatory efforts are the foundation for commerce enhancing the vitality of the internet.

Business accountability, data stewardship and data protection are equally important privacy issues. Any proposed privacy framework needs to address practical protection for consumer data from abuse, exploit, breach and loss without compromising business’ security and fraud detection capabilities. Concurrently, OTA believes any changes to the regulatory landscape will also need to address the potential negative and disruptive impact to ad-supported content services, innovation, and commerce.

The OTA looks forward to continued collaboration with browser vendors, trade organizations, government agencies and advocacy groups in advancing the goal of consumer trust and online confidence. On behalf of the Board and membership of OTA we look forward to continued dialog on these issues.

Sincerely,

Craig Spiezle
Executive Director & President
Online Trust Alliance
https://otalliance.org

Submission Number: 00300

Received:2/16/2011 10:09:10 AM
Commenter: Ann Waldo
Organization:Wolters Kluwer Pharma Solutions
State:District of Columbia
Attachments: 00300-57631.pdf Size: 415 KB

Submission Number: 00301

Received:2/16/2011 10:17:58 AM
Commenter: ThomasLenard
Organization:Technology Policy Institute
State:District of Columbia
Attachments: 00301-57629.pdf Size: 274 KB DoC: Lenard_DOCPrivacyComments.pdf

 

Submission Number: 00302

Received:2/16/2011 11:15:31 AM
Commenter: ShawnKaminski
Organization:American Bar Association, Section of science & Technology Law
State:Illinois
Attachments: 00302-57630.pdf Size: 374 KB

Submission Number: 00303

Received:2/16/2011 11:21:19 AM
Commenter: RobertRichards, Jr.
Organization:Aero-Metric, Inc.
State:Wisconsin
Good Day. Our firm is an aerial mapping firm that provides full-service geospatial solution services to its clients. I am respectfully urging the FTC not to implement any enforcement or broad regulation that would have a harmful affect on firms like mine in the broad private geospatial community. Specifically, the FTC report imprecisely uses and regulates the term “precise geolocation information” or “precise geolocation data”. This would adversely impact consumers, geospatial firms, and government programs. My firm is particularly concerned that this term was not defined in the FTC staff report and the proposed regulations will have broad and harmful unintended consequences. The use of the term “geolocation” or other geospatial relevant terminology that appear in the FTC regulations will impose a significant new liability on my firm. It regulates areas of the economy and geospatial activities that have not been identified as a problem or pose any privacy concern to citizens. The regulations could thwart common, legitimate, and emerging uses of geospatial data for emergency response/post disaster remediation, insurance, environmental protection, E-911 & ambulance services, fleet management broadband mapping, home security, navigation, mortgage foreclosure monitoring/early warning system, and others. Moreover, activities, technologies, and applications development could be deemed illegal. For example, it would be impractical, if not impossible, for my firm to obtain prior approval or consent from individual citizens prior to acquiring or applying data such as satellite imagery, aerial photography, or parcel, address, or transportation data. The FTC regulation would effectively ban my firm, or our clients, from important value-added, integration and application activities. Finally, any such FTC regulation could put U.S. companies at a significant and insurmountable competitive disadvantage against foreign firms that may not be covered by that regulation, or for which enforcement would be impractical. FTC should provide the necessary and desirable privacy protections to individual citizens; however, it should not limit the geospatial community’s ability to grow, prosper, and bring to the market those technologies and applications that meet the economic demands of consumers and citizens. In conclusion, I would like to point out that many states define a number of geospatial or geolocation activities as the practice of professional surveying. Therefore, practitioners are licensed and regulated by the government – state licensing boards. Consumers are then already protected.

Submission Number: 00304

Received:2/16/2011 4:16:34 PM
Commenter: BrianBurnett
Organization:Bohannan Huston
State:New Mexico
I am President of a company that provides geospatial (mapping and surveying) information to many private and public sector customers. I respectfully urge the FTC not to implement any enforcement or broad regulation that would have a harmful affect on firms like mine in the broad private geospatial community. Specifically, the FTC report imprecisely uses and regulates the term “precise geolocation information” or “precise geolocation data” which could adversely impact consumers, geospatial firms, and government programs. We are particularly concerned that these terms were not defined in the FTC staff report and the proposed regulations. As such, we believe that this will have broad and harmful unintended consequences, along with adding a significant new liablity on my company. Such terms may end up regulating areas of the economy and geospatial activities
that have not been identified as a problem or pose any privacy concern to citizens. If left in the current form, the regulations could thwart common, legitimate, and emerging uses of geospatial data for emergency response/post disaster remediation, insurance, environmental protection, E-911 & ambulance services, fleet
management broadband mapping, home security, navigation, mortgage foreclosure monitoring/early warning systems, and others.
Moreover, activities, technologies, and applications development could be deemed illegal. For example, it would be very impractical, if not impossible, for my firm to obtain prior approval or consent from individual citizens prior to acquiring or applying data such as satellite imagery, aerial photography, or parcel, address, or
transportation data. The FTC regulation would effectively ban my firm, or our clients, from important valueadded, integration and application activities. Finally, any such FTC regulation could put U.S. companies at a significant and insurmountable competitive
disadvantage against foreign firms that may not be covered by that regulation, or for which enforcement would be impractical. The FTC should provide the necessary and desirable privacy protections to individual citizens; however, I believe it should do so in a manner that does not limit the geospatial community’s ability to grow, prosper, and bring to the market those technologies and applications that meet the economic demands of consumers and citizens. Thank you very much for allowing me to comment on this very important issue.

Submission Number: 00305

Received:2/17/2011 5:37:55 AM
Commenter: SilkeHarz
Organization:The Federal Commissioner for Data Protection and Freedom of Information
State:Outside the United States
Attachments: 00305-57635.pdf Size: 21 KB
16 February 2011

FTC Preliminary Staff Report: “Protecting Consumers Privacy in an Era of Rapid Change: A Proposed Framework for Businesses and Policymakers”

Contribution by the German Federal Commissioner for Data Protection
and Freedom of Information

The BfDI welcomes the opportunity to submit comments on the FTC Preliminary Staff Report “Protecting Consumers Privacy in an Era of Rapid Change: A Proposed Framework for Businesses and Policymakers”.

The report contains many important suggestions for improvement in the area of data protection. In particular, the proposal to introduce a “do not track mechanism” is of high relevance. By this suggestion the FTC faces up to one of the biggest privacy issues on the Internet: The creation of comprehensive user profiles.

Also the European Parliament has determined in the so-called ePrivacy Directive (Article 5 paragraph 3) that tracking mechanisms, such as the setting of persistent cookies, is only allowed with the data subject’s explicit consent on the basis of comprehensive information. The “do not track me” approach now favored by the FTC offers a practical example to fill the relevant regulation in the ePrivacy Directive with life. However, the FTC solution should also include the preset of this option in the respective program. Then the data subject would have to agree to an activation of the tracking function himself by clicking the appropriate button (no tracking by default).

Given the high relevance of this issue the Federal Commissioner would be very interested in a further exchange of information with the FTC, in particular as regards the implementation of the proposed measure.

Submission Number: 00306

Received:2/17/2011 9:50:47 AM
Commenter: TerryKeating
Organization:Aerometric
State:Wisconsin
The aerial mapping community trusts that the intent of this legislation is not to require that everyone gets notified and must give permission before we can make or deliver a map. Please fix the wording and intent of the law so you do not create a bigger mess regarding geolocation privacy.

Submission Number: 00307

Received:2/17/2011 10:56:16 AM
Commenter: RussellSchrader
Organization:Visa Inc.
State:California
Attachments: 00307-57657.pdf Size: 29 KB DoC: Visa.pdf

 

Submission Number: 00308

Received:2/17/2011 11:20:22 AM
Commenter: SandraTroutman
Organization:Mortgage Bankers Association
State:District of Columbia
Attachments: 00308-57658.pdf Size: 123 KB DoC: MBA Privacy Comment Letter.pdf
Please find our comments attached concerning, the preliminary FTC staff report, “Protecting Consumer Privacy in an Era of Rapid Change.”

Thank you,
Sandra Troutman

Submission Number: 00309

Received:2/17/2011 12:04:59 PM
Commenter: JamesMain
Organization:Main Aerial
State:Arizona
I respectfully urge the FTC not to implement any enforcement or broad regulation that would have a harmful
affect on firms like mine in the broad private geospatial community.
Specifically, the FTC report imprecisely uses and regulates the term “precise geolocation information” or
“precise geolocation data”. This would adversely impact consumers, geospatial firms, and government
programs. My firm is particularly concerned that this term was not defined in the FTC staff report and the
proposed regulations will have broad and harmful unintended consequences. The use of the term “geolocation” or other geospatial relevant terminology that appear in the FTC regulations
will impose a significant new liability on my firm. It regulates areas of the economy and geospatial activities
that have not been identified as a problem or pose any privacy concern to citizens.
The regulations could thwart common, legitimate, and emerging uses of geospatial data for emergency
response/post disaster remediation, insurance, environmental protection, E-911 & ambulance services, fleet
management broadband mapping, home security, navigation, mortgage foreclosure monitoring/early warning
system, and others.
Moreover, activities, technologies, and applications development could be deemed illegal. For example, it
would be impractical, if not impossible, for my firm to obtain prior approval or consent from individual citizens
prior to acquiring or applying data such as satellite imagery, aerial photography, or parcel, address, or
transportation data. The FTC regulation would effectively ban my firm, or our clients, from important value added,
integration and application activities.
Finally, any such FTC regulation could put U.S. companies at a significant and insurmountable competitive
disadvantage against foreign firms that may not be covered by that regulation, or for which enforcement would
be impractical.
FTC should provide the necessary and desirable privacy protections to individual citizens; however, it should
not limit the geospatial community’s ability to grow, prosper, and bring to the market those technologies and
applications that meet the economic demands of consumers and citizens.

Submission Number: 00310

Received:2/17/2011 12:18:09 PM
Commenter: Pierrele Roux
Organization:Private
State:Alabama
Sir/Madam

I support your concern regarding privacy issues. In order to provide true privacy though we need to strongly consider infrastructures and legislation that protect individuals first. To this end I propose that you consider “Do Track/Call/Mail” mechanisms instead of “Do Not Track/Call/Mail” mechanisms , ie. opt-in rather than opt-out.

In this scenario business and marketeers cannot and should not be allowed to track, mail, call etc. unless someone has specifically opted in. Yes – it will make it more difficult for business to market, but it will also go a long way to protection of individual rights and privacy.

Thank you

Pierre le Roux

Submission Number: 00311

Received:2/17/2011 12:29:28 PM
Commenter: MargaretHoward
Organization:CompassCom Software Corp
State:Colorado
Attachments: 00311-57660.pdf Size: 649 KB
Please see the attached response for CompassCom Software Corporation.

Thank you!

Submission Number: 00312

Received:2/17/2011 12:31:43 PM
Commenter: W. BrantHoward
Organization:CompassData, Inc.
State:Colorado
Attachments: 00312-57661.pdf Size: 24 KB
Please see the attached response for CompassData, Inc.

Thank you!

Submission Number: 00313

Received:2/17/2011 12:35:55 PM
Commenter: SteveChiles
Organization:CompassTools, Inc.
State:Colorado
Attachments: 00313-57663.pdf Size: 21 KB
Please see the attached response for CompassTools, Inc.

Thank you!

Submission Number: 00314

Received:2/17/2011 12:49:54 PM
Commenter: NadineSease
Organization:Metro Geospatial LLC
State:Georgia
I respectfully urge the FTC not to implement any enforcement or broad regulation that would have a harmful affect on firms like mine in the broad private geospatial community.

Specifically, the FTC report imprecisely uses and regulates the term “precise geolocation information” or “precise geolocation data”. This would adversely impact consumers, geospatial firms, and government programs. My firm is particularly concerned that this term was not defined in the FTC staff report and the proposed regulations will have broad and harmful unintended consequences.

The use of the term “geolocation” or other geospatial relevant terminology that appear in the FTC regulations will impose a significant new liability on my firm. It regulates areas of the economy and geospatial activities that have not been identified as a problem or pose any privacy concern to citizens.

The regulations could thwart common, legitimate, and emerging uses of geospatial data for emergency response/post disaster remediation, insurance, environmental protection, E-911 & ambulance services, fleet management broadband mapping, home security, navigation, mortgage foreclosure monitoring/early warning system, and others.

Moreover, activities, technologies, and applications development could be deemed illegal. For example, it would be impractical, if not impossible, for my firm to obtain prior approval or consent from individual citizens prior to acquiring or applying data such as satellite imagery, aerial photography, or parcel, address, or
transportation data. The FTC regulation would effectively ban my firm, or our clients, from important valueadded, integration and application activities.

Finally, any such FTC regulation could put U.S. companies at a significant and insurmountable competitive disadvantage against foreign firms that may not be covered by that regulation, or for which enforcement would be impractical.

FTC should provide the necessary and desirable privacy protections to individual citizens; however, it should not limit the geospatial community’s ability to grow, prosper, and bring to the market those technologies and applications that meet the economic demands of consumers and citizens.

Submission Number: 00315

Received:2/17/2011 12:54:54 PM
Commenter: PamHoran
Organization:Online Publishers Association
State:New York
Attachments: 00315-57664.pdf Size: 84 KB DoC: OPA Comments in DOC Privacy Proceeding (Docket No. 101214614-0614-01).pdf
Attached, please find the comments of the Online Publishers Association (OPA) in response to the Commission’s request for comments on its preliminary staff report, “Protecting Consumer Privacy in an Era of Rapid Change: A Proposed Framework for Businesses and Policymakers.” OPA appreciates the opportunity to comment on the report, and looks forward to participating in the Commission’s considerations on these issues going forward.

If you have any questions or concerns regarding the comments, please let me know.

Regards,
Patrick Byrnett
Counsel to Online Publishers Association

Submission Number: 00316

Received:2/17/2011 1:18:55 PM
Commenter: QuinnJalli
Organization:Epsilon
State:New York
Attachments: 00316-57665.pdf Size: 80 KB

Submission Number: 00317

Received:2/17/2011 1:28:44 PM
Commenter: MichaelMain
Organization:Main Aerial Photography
State:Arizona
I respectfully urge the FTC not to implement any enforcement or broad regulation that would have a harmful
affect on firms like mine in the broad private geospatial community.
Specifically, the FTC report imprecisely uses and regulates the term “precise geolocation information” or
“precise geolocation data”. This would adversely impact consumers, geospatial firms, and government
programs. My firm is particularly concerned that this term was not defined in the FTC staff report and the
proposed regulations will have broad and harmful unintended consequences.
The use of the term “geolocation” or other geospatial relevant terminology that appear in the FTC regulations
will impose a significant new liability on my firm. It regulates areas of the economy and geospatial activities
that have not been identified as a problem or pose any privacy concern to citizens.
The regulations could thwart common, legitimate, and emerging uses of geospatial data for emergency
response/post disaster remediation, insurance, environmental protection, E-911 & ambulance services, fleet
management broadband mapping, home security, navigation, mortgage foreclosure monitoring/early warning
system, and others.
Moreover, activities, technologies, and applications development could be deemed illegal. For example, it
would be impractical, if not impossible, for my firm to obtain prior approval or consent from individual citizens
prior to acquiring or applying data such as satellite imagery, aerial photography, or parcel, address, or
transportation data. The FTC regulation would effectively ban my firm, or our clients, from important valueadded,
integration and application activities.
Finally, any such FTC regulation could put U.S. companies at a significant and insurmountable competitive
disadvantage against foreign firms that may not be covered by that regulation, or for which enforcement would
be impractical.
FTC should provide the necessary and desirable privacy protections to individual citizens; however, it should
not limit the geospatial community’s ability to grow, prosper, and bring to the market those technologies and
applications that meet the economic demands of consumers and citizens.

Submission Number: 00318

Received:2/17/2011 1:48:39 PM
Commenter: DanielMarsh
Organization:GRW Aerial Surveys, Inc.
State:Kentucky
I respectfully urge the FTC not to implement any enforcement or broad regulation that would have a harmful
affect on firms like mine in the broad private geospatial community.
Specifically, the FTC report imprecisely uses and regulates the term “precise geolocation information” or
“precise geolocation data”. This would adversely impact consumers, geospatial firms, and government
programs. My firm is particularly concerned that this term was not defined in the FTC staff report and the
proposed regulations will have broad and harmful unintended consequences.
The use of the term “geolocation” or other geospatial relevant terminology that appear in the FTC regulations
will impose a significant new liability on my firm. It regulates areas of the economy and geospatial activities
that have not been identified as a problem or pose any privacy concern to citizens.
The regulations could thwart common, legitimate, and emerging uses of geospatial data for emergency
response/post disaster remediation, insurance, environmental protection, E-911 & ambulance services, fleet
management broadband mapping, home security, navigation, mortgage foreclosure monitoring/early warning
system, and others.
Moreover, activities, technologies, and applications development could be deemed illegal. For example, it
would be impractical, if not impossible, for my firm to obtain prior approval or consent from individual citizens
prior to acquiring or applying data such as satellite imagery, aerial photography, or parcel, address, or
transportation data. The FTC regulation would effectively ban my firm, or our clients, from important valueadded,
integration and application activities.
Finally, any such FTC regulation could put U.S. companies at a significant and insurmountable competitive
disadvantage against foreign firms that may not be covered by that regulation, or for which enforcement would
be impractical.
FTC should provide the necessary and desirable privacy protections to individual citizens; however, it should
not limit the geospatial community’s ability to grow, prosper, and bring to the market those technologies and
applications that meet the economic demands of consumers and citizens.

Submission Number: 00319

Received:2/17/2011 1:55:21 PM
Commenter: SharonFranklin
Organization:The Constitution Project
State:District of Columbia
Attachments: 00319-57666.pdf Size: 63 KB
Please see attached PDF for the Constitution Project’s comments in response to the FTC’s report entitled “Protecting Consumer Privacy in an Era of Rapid Change: A Proposed Framework for Businesses and Policymakers.”

Submission Number: 00320

Received:2/17/2011 2:14:11 PM
Commenter: AdamThierer
Organization:Mercatus Center
State:Virginia
Attachments: 00320-57670.pdf Size: 753 KB

Submission Number: 00321

Received:2/17/2011 2:21:08 PM
Commenter: Brad Wiskirchen
Organization:Kount, Inc.
State:Idaho
Attachments: 00321-57671.pdf Size: 3365 KB

Submission Number: 00322

Received:2/17/2011 2:26:14 PM
Commenter: Brad Wiskirchen
Organization:ClickBank
State:Idaho
Attachments: 00322-57672.pdf Size: 4124 KB

Submission Number: 00323

Received:2/17/2011 2:39:37 PM
Commenter: ReedFreeman
Organization:Email Sender & Provider Coalition
State:Maine
Attachments: 00323-57673.pdf Size: 8649 KB
Attached please find the comments of the Email Sender & Provider Coalition regarding the Preliminary FTC Staff Report on “Protecting Consumer Privacy in an Era of Rapid Change: A Proposed Framework for Businesses and Policymakers.”

Submission Number: 00324

Received:2/17/2011 2:40:03 PM
Commenter: MitchellLong
State:Kentucky
I respectfully urge the FTC not to implement any enforcement or broad regulation that would have a detrimental affect on geospatial community.

Specifically, the FTC report imprecisely uses and regulates the term “precise geolocation information” or “precise geolocation data”. This would adversely impact my firm, job, and co-workers. Not to mention existing clients, potential consumers, other geospatial firms, and state and government programs. I am chiefly troubled that this term was not defined in the FTC staff report and the proposed regulations will have broad and damaging unintended consequences.

The use of the term “geolocation” or other geospatial relevant terminology that appear in the FTC regulations will impose a significant liability on my firm where I work. It regulates areas of the economy and geospatial activities that have not been identified as a problem or pose any privacy concern to citizens.

The regulations could halt or deem illegal, common, legitimate, and emerging uses of geospatial data for environmental protection, emergency response/post disaster remediation, E-911 & ambulance services, infrastructure design and maintanience, home security, navigation, airspace safety, just to mention a few.

Finally, any such FTC regulation could put U.S. companies at a
significant and insurmountable competitive disadvantage against foreign firms that may not be covered by that regulation, or for which enforcement would be impractical.

FTC should provide the necessary and desirable privacy protections to individual citizens; however, it should not limit the geospatial community’s ability to grow, prosper, and bring to the market those technologies and applications that meet the economic demands of consumers and citizens.

Submission Number: 00325

Received:2/17/2011 2:55:13 PM
Commenter: RichardCrouse
Organization:Richard Crouse & Associates
State:Maryland
I am concerned that language in the staff report concerning “precise geolocation information” may have unintended negative consequences for our national interests. Richard Crouse and Associates, Inc. collects aerial survey data using metric cameras and other devices for use in producing maps and other geospatial products. These products are numerous, span many disciplines and are an integral part of our nation’s infrastructure and land management. Many are also governmental in nature. While privacy considerations are very important, the Commission should take great care not to hamper the efforts of our profession by creating unnecessary liabilities or other onerous regulations.

Submission Number: 00326

Received:2/17/2011 3:12:13 PM
Commenter: ClarissaCerda
Organization:LifeLock, Inc.
State:Arizona
Attachments: 00326-57729.pdf Size: 156 KB DoC: LifeLock Green Paper Comments (01-27-2011)(final) (3).pdf

 

Submission Number: 00327

Received:2/17/2011 3:12:22 PM
Commenter: MatthewHaies
Organization:PrivaCeed Inc.
State:New York
Attachments: 00327-57730.pdf Size: 166 KB

Submission Number: 00328

Received:2/17/2011 3:38:56 PM
Commenter: WilliamMcKeague
State:Virginia
I respectfully urge the FTC not to implement any broad regulation that would have a harmful effect on firms like mine in the broad private geospatial community.

The use of the term “geolocation” or other geospatial relevant terminology that appear in the FTC regulations will impose a significant new liability on my firm. It regulates areas of the economy and geospatial activities that have not been identified as a problem or pose any privacy concern to citizens.

FTC should provide the necessary and desirable privacy protections to individual citizens; however, it should not limit the geospatial community’s ability to grow, prosper, and bring to the market those technologies and applications that meet the economic demands of consumers and citizens.

Submission Number: 00329

Received:2/17/2011 3:56:48 PM
Commenter: MarkSableman
Organization:American Business Media
State:Missouri
Attachments: 00329-57732.pdf Size: 461 KB DoC: ABM comments to 12-2010 Commerce Privacy Report.pdf

 

Submission Number: 00330

Received:2/17/2011 4:00:16 PM
Commenter: Brad Wiskirchen
Organization:Kount, Inc.
State:Idaho
Attachments: 00330-57733.pdf Size: 1199 KB

Submission Number: 00331

Received:2/17/2011 4:49:08 PM
Commenter: JeffreyFrancer
Organization:Pharmaceutical Research and Manufacturers of America
State:District of Columbia
Attachments: 00331-57734.pdf Size: 148 KB
Please see attached comments.

Submission Number: 00332

Received:2/17/2011 5:20:11 PM
Commenter: BradWeltman
Organization:Magazine Publishers of America
State:District of Columbia
Attachments: 00332-57738.pdf Size: 193 KB

Submission Number: 00333

Received:2/17/2011 6:10:37 PM
Commenter: ColinWatson
Organization:OWASP Foundation
State:Maryland
Attachments: 00333-57739.pdf Size: 82 KB

Submission Number: 00334

Received:2/17/2011 6:47:19 PM
Commenter: StevenVine
Organization:Datran Media
State:New York
Attachments: 00334-57756.pdf Size: 497 KB
Datran Media appreciates the opportunity to participate in the public comments on the Preliminary FTC Staff Report entitled “Protecting Consumer Privacy in an Era of Rapid Change: A Proposed Framework for Businesses and Policymakers.” Please see our attached comments.

Submission Number: 00335

Received:2/17/2011 7:17:44 PM
Commenter: MichaelGeroe
Organization:Adknowledge, Inc.
State:Missouri
Attachments: 00335-57758.pdf Size: 513 KB
Please find attached in PDF format the comments of Adknowledge, Inc.

Submission Number: 00336

Received:2/18/2011 4:51:10 AM
Commenter: PatrickWalshe
Organization:GSMA
State:Outside the United States
Attachments: 00336-57840.pdf Size: 406 KB
00336-57841.pdf Size: 136 KB
The GSMA welcomes the opportunity to comment on the FTC’s preliminary report into consumer privacy. We look forward to engaging with the FTC and other stakeholders in dialogue in the interests of addressing consumer privacy issues and challenges.

Submission Number: 00337

Received:2/18/2011 5:33:41 AM
Commenter: patriciaziegler
Organization:GRW Aerial surveys
State:Kentucky
I have been in the geospatial business for over 20 years. This appears to have wide spread unintended consequences by severely limiting the information we collect.

Submission Number: 00338

Received:2/18/2011 6:14:26 AM
Commenter: JeffChester
Organization:Center for Digital Democracy
State:District of Columbia
Attachments: 00338-57839.pdf Size: 223 KB    DoC: CDDUSPIRGPrivacyComments.pdf
CDD and US PIRG are pleased to submit these comments concerning the Preliminary FTC Staff Report on “Protecting Consumer Privacy in an Era of Rapid Change: A Proposed Framework for Businesses and Policymakers.

Submission Number: 00339

Received:2/18/2011 7:10:19 AM
Commenter: MarkLieberman
Organization:TRA
State:New York
Attachments: 00339-57759.pdf Size: 66 KB
Attached are the Comments of TRA.

Submission Number: 00340

Received:2/18/2011 7:35:39 AM
Commenter: MarvinMiller
Organization:AeroMetric, Inc.
State:Minnesota
I respectfully urge the FTC not to implement any enforcement or broad regulation that would have a harmful
affect on firms like mine in the broad private geospatial community.
Specifically, the FTC report imprecisely uses and regulates the term “precise geolocation information” or
“precise geolocation data”. This would adversely impact consumers, geospatial firms, and government
programs. My firm is particularly concerned that this term was not defined in the FTC staff report and the
proposed regulations will have broad and harmful unintended consequences.
The use of the term “geolocation” or other geospatial relevant terminology that appear in the FTC regulations
will impose a significant new liability on my firm. It regulates areas of the economy and geospatial activities
that have not been identified as a problem or pose any privacy concern to citizens.
The regulations could thwart common, legitimate, and emerging uses of geospatial data for emergency
response/post disaster remediation, insurance, environmental protection, E-911 & ambulance services, fleet
management broadband mapping, home security, navigation, mortgage foreclosure monitoring/early warning
system, and others.
Moreover, activities, technologies, and applications development could be deemed illegal. For example, it
would be impractical, if not impossible, for my firm to obtain prior approval or consent from individual citizens
prior to acquiring or applying data such as satellite imagery, aerial photography, or parcel, address, or
transportation data. The FTC regulation would effectively ban my firm, or our clients, from important valueadded,
integration and application activities.
Finally, any such FTC regulation could put U.S. companies at a significant and insurmountable competitive
disadvantage against foreign firms that may not be covered by that regulation, or for which enforcement would
be impractical.
FTC should provide the necessary and desirable privacy protections to individual citizens; however, it should
not limit the geospatial community’s ability to grow, prosper, and bring to the market those technologies and
applications that meet the economic demands of consumers and citizens.

Submission Number: 00341

Received:2/18/2011 8:27:27 AM
Commenter: Jules Polonetsky
Organization:Future of Privacy Forum
State:District of Columbia
Attachments: 00341-57842.pdf Size: 148 KB DoC: DOC029.PDF
Please see the attached letter from:

Jules Polonetsky
Director and Co-chair
Future of Privacy Forum

Christopher Wolf
Founder and Co-chair
Future of Privacy Forum

Submission Number: 00342

Received:2/18/2011 9:13:01 AM
Commenter: PeterSwire
Organization:Ohio State University/Center for American Progress
State:Ohio
Attachments: 00342-57843.pdf Size: 284 KB DoC: SwireComment.PDF
To the Federal Trade Commission. Attached please find my comments, entitled “Social Networks, Privacy, and Freedom of Association.” Thank you,

Professor Peter Swire
C. William O’Neill Professor of Law
Ohio State University

and

Senior Fellow
Center for American Progress

Submission Number: 00343

Received:2/18/2011 9:22:31 AM
Commenter: OrenNetzer
Organization:DoubleVerify
State:New York
Attachments: 00343-57847.pdf Size: 296 KB

Submission Number: 00344

Received:2/18/2011 9:44:22 AM
Commenter: MikeGassewitz
Organization:KINDSIGHT
State:Outside the United States
Attachments: 00344-57850.pdf Size: 247 KB    DoC: Kindsight Privacy Comments 1-28-11.pdf

 

Submission Number: 00345

Received:2/18/2011 9:48:21 AM
Commenter: ZacharyRodgers
Organization:ClickZ
State:New York
Attachments: 00345-57852.pdf Size: 174 KB
Incisive Media’s ClickZ, an ad-supported online publication, has been the largest resource of interactive marketing news, commentary, and how-to information since it was established in 1997.

ClickZ recognizes that the commission’s do-not-track proposal is the most significant regulatory initiative ever to be introduced during the short life of the online ad industry. For this reason, ClickZ’s editorial staff wanted to ensure our readers – comprised of the top digital marketing professionals in the U.S. – shared their thoughts about the implications of do-not-track on this burgeoning sector of the economy.

The attached summary outlines responses submitted by 17 readers and columnists, supplemented with information reported by staff journalists. Thank you for the opportunity to weigh in on this crucial privacy issue.

Regards,
The ClickZ Team
ClickZ.com

Submission Number: 00346

Received:2/18/2011 9:53:52 AM
Commenter: GuilhermeRoschke
Organization:Institute for Public Representation
State:District of Columbia
Attachments: 00346-57870.pdf Size: 249 KB    DoC: CommerceLetter.pdf COPPA_Final.pdf
Attached please find the Comments of a Coalition of Child, Health, and Consumer Advocates. Specifically: Center for Digital Democracy, American Academy of Child and Adolescent Psychiatry, American Academy of Pediatrics, Berkeley Media Studies Group, a project of the Public Health Institute, Children Now, Consumer Federation of America, Consumer Watchdog, David VB Britt, Retired CEO, Sesame Workshop, Ellen Wartella, Kathryn Montgomery, National Policy & Legal Analysis Network to Prevent Childhood Obesity, a project of Public Health Law & Policy, The Praxis Project, Privacy Rights Clearinghouse, Public Good, Public Health Institute, Tamara R. Piety, and World Privacy Forum

Submission Number: 00347

Received:2/18/2011 10:39:50 AM
Commenter: ChrisHoofnagle
Organization:Berkeley Center for Law & Technology
State:California
Attachments: 00347-57879.pdf Size: 182 KB DoC: hoofnagle_doc_comments.pdf
See attached.

Submission Number: 00348

Received:2/18/2011 10:59:05 AM
Commenter: AmandaPedigo
Organization:Intuit
State:District of Columbia
Attachments: 00348-57880.pdf Size: 182 KB DoC: Intuit.pdf
Intuit respectfully submits its comments to the FTC Report, in the attachment. Thank you for the opportunity.

Submission Number: 00349

Received:2/18/2011 11:19:32 AM
Commenter: Tina Grande
Organization:Confidentiality Coalition c/o the Healthcare Leadership Council
State:District of Columbia
Attachments: 00349-57883.pdf Size: 90 KB
Please see attached Confidentiality Coalition Comments on the FTC Staff Report “Protecting Consumer Privacy in an Era of Rapid Change.”

Please contact Tina Grande, SVP for Policy, Healthcare Leadership Council at tgrande@hlc.org or (202) 452-8700 if you have questions or need additional information.

Thank you for the opportunity to comment.

Submission Number: 00350

Received:2/18/2011 11:42:54 AM
Commenter: IraRubinstein
Organization:New York University School of Law
State:New York
Attachments: 00350-57884.pdf Size: 750 KB DoC: Rubinstein_Hirsch_Comments_on_Privacy_Green_Paper.pdf
Attached please find my comments.

 

Thanks
Ira Rubinstein

Submission Number: 00351

Received:2/18/2011 11:51:11 AM
Commenter: BethGivens
Organization:Privacy Rights Clearinghouse
State:California
Attachments: 00351-57885.pdf Size: 485 KB DoC: CommerceDept-PrivacyGreenPaper-PRCComments-Jan28-2011.pdf
Please see attached comments from the Privacy Rights Clearinghouse.

Submission Number: 00352

Received:2/18/2011 11:53:03 AM
Commenter: DougThompson
Organization:Retail Industry Leaders Association
State:Virginia
Attachments: 00352-57871.pdf Size: 445 KB
00352-57872.pdf Size: 165 KB
00352-57873.pdf Size: 28 KB DoC: Commerce Privacy Final Comment Letter 1 28 11 DT edits.pdf
Please see attached letter and exhibits below.
Doug Thompson
Vice President, Government Affairs
Retail Industry Leaders Association

Submission Number: 00353

Received:2/18/2011 12:09:15 PM
Commenter: BrooksDobbs
Organization:Phorm Inc.
State:Georgia
Attachments: 00353-57888.pdf Size: 140 KB
Attached are Phorm’s comments with respect to the Commission’s proposed privacy framework for business and policymakers.

Submission Number: 00354

Received:2/18/2011 12:16:44 PM
Commenter: IvanDeLoatch
Organization:US Geological Survey/Federal Geographic Data Committee Secretariat
State:Virginia
Attachments: 00354-57961.pdf Size: 56 KB
Please see attached comment.

Submission Number: 00355

Received:2/18/2011 12:26:12 PM
Commenter: CCalderone
State:California
Comments on FTC Proposed Privacy Framework

I offer the following simple proposals in response to requests for comments:

In order to improve consumer understanding, require websites to have periodic (monthly) audit and updates to the consumer privacy choices. As they return to the website, consumers will have a higher probability of reading important language and understanding their choices. At the same time, the company would have the consumer accept the Privacy Policy multiple times, making informed consent more reliable.

The FTC “call to increase transparency” seems counterproductive. What consumer is going to understand all the implications of allowing meta-data collection? Even putting it into plain English and saying whether data is scrubbed or tokenized is unlikely to promote real understanding and awareness. I believe more good would come from the FTC publishing minimum standards for safeguarding information.

FTC could and should set universal privacy definitions and the use of a logo or identifiable mark makes sense. What a certain “privacy” standard means needs to be consistent and understood by both retailers and consumers as they move from site to site.
Standard definitions will also help the companies research, plan, and set their privacy policy levels to correspond to the definitions. Moreover, it would be beneficial to understand how, if they use tokenization or other anonymizing technology to scrub personally identifiable information, they meet a certain level of personal privacy.

Let us assume that people are generally not pro-active. The FTC acknowledges that people will not read more than a quick blurb or two about their privacy rights and have required shorter policies. To further assist with this, a defined and coded simple standard will do far more to protect consumers than elaborate “by design” models will. As an attorney, even I do not read complete privacy policies on many of the websites I visit. However, a simple blurb, or a “PG” rating and a link to a wiki definition, would be easy for anyone to understand.

p. 20/122-Enforcement? Look at what works for Facebook. It is not the their Privacy Policy approach that matters, but rather the reactions of the user community. Let “FTC Approved” labels go on websites that “Say what they do and do what they say.” Good Housekeeping type seal of approval can and would work. If it is part of a licensing process, fees could be charged to offset the FTC costs. This would allow pro-active compliance instead of reactive to complaints of criminal behavior or malfeasance. The example to follow might be that of becoming a member of the EU Data Protection Act’s Safe Harbor provision.

Why do consumers need to have access to “their data?” In most instances, the only safe option is to have it anonymized and/or deleted.

“Do Not Track” makes little sense because some tracking is necessary for security purposes. Also, a main reason for collecting cookie data is to keep the consumer experience positive. If “do not track” means having to re-enter all data, even when you are checking on shipping for a previously placed order, then it will never be an acceptable choice for a consumer. There may still be indirect tracking so why not allow certain information for the purposes of support and troubleshooting. Company websites would need to have consumers consent to waiving their DNT rights in order to do business on the site. Once this occurs then DNT is likely to have no effect. Another argument would be that there can be a public benefit to knowing basic site traffic information similar to a Nielsen rating for a television broadcast. For example, wouldn’t the FTC benefit by monitoring information on how many website visitors actually click or scroll on the Privacy Policy?

Submission Number: 00356

Received:2/18/2011 12:33:23 PM
Commenter: DianeBowers
Organization:CASRO (Council of American Survey Research Organizations)
State:New York
Attachments: 00356-57962.pdf Size: 167 KB
00356-57963.pdf Size: 1025 KB
On behalf of CASRO, I am submitting the attached letter, providing support for and suggestions regarding the FTC’s Privacy Report and Proposed Framework. In additional, we have attached a copy of the CASRO Code of Standards for Survey Research.

In response to the FTC’s mention of the need for additional survey research–marketing, opinion, and social research–regarding privacy issues, CASRO offers our assistance and support of this objective. Please let us know if we can help.

Sincerely, Diane Bowers, President

Submission Number: 00357

Received:2/18/2011 12:52:53 PM
Commenter: MeredithHalama
Organization:NAI
State:District of Columbia
Attachments: 00357-57964.pdf Size: 146 KB DoC: NAICommerceGreenPaperComments0128.pdf
Attached please find the comments of the Network Advertising Initiative regarding the Preliminary FTC Staff Report, “Protecting Consumer Privacy in an Era of Rapid Change: A Proposed Framework for
Businesses and Policymakers.”

Submission Number: 00358

Received:2/18/2011 1:02:42 PM
Commenter: SusanGrant
Organization:Consumer Federation of America
State:District of Columbia
Attachments: 00358-57965.pdf Size: 300 KB DoC: CFA DOC Comments 1.2011.pdf
The comments of the Consumer Federation of America on the Preliminary FTC Staff Report on “Protecting Consumer Privacy in an Era of Rapid Change: A Proposed Framework for Businsses and Policymakers” are attached.

Submission Number: 00359

Received:2/18/2011 1:10:04 PM
Commenter: RandalPicker
Organization:The University of Chicago Law School
State:Illinois
Attachments: 00359-57966.pdf Size: 195 KB

Submission Number: 00360

Received:2/18/2011 1:11:00 PM
Commenter: Martin E.Abrams
Organization:The Centre for Information Policy Leadership at Hunton & Williams LLP
State:District of Columbia
Attachments: 00360-57967.pdf Size: 918 KB DoC: Centre’s Response to the DOC (Docket No. 101214614-0614-01).PDF
Attached please find the Centre for Information Policy Leadership’s response to the Federal Trade Commission (“FTC”) preliminary report, “Protecting Consumer Privacy in an Era of Rapid Change: A Proposed Framework for Businesses and Policymakers.”

Submission Number: 00361

Received:2/18/2011 1:15:39 PM
Commenter: SteveDelBianco
Organization:NetChoice
State:District of Columbia
Attachments: 00361-57968.pdf Size: 709 KB DoC: NetChoice Comments on Commerce Green Paper FINAL.pdf
Reply comments from NetChoice are attached

Submission Number: 00362

Received:2/18/2011 1:17:47 PM
Commenter: IoanaRusu
Organization:Consumers Union
State:District of Columbia
Attachments: 00362-57969.pdf Size: 62 KB DoC: DoC Privacy Report – CU Comments – 1.28.11.pdf
Please see comments attached.

Submission Number: 00363

Received:2/18/2011 1:21:59 PM
Commenter: EricEllman
Organization:Consumer Data Industry Association
State:District of Columbia
Attachments: 00363-57972.pdf Size: 225 KB DoC: Consumer Data Industry Association.pdf

 

Submission Number: 00365

Received:2/18/2011 1:31:43 PM
Commenter: Edward Kabak
Organization:Promotion Marketing Association,Inc
State:New York
Attachments: 00365-57973.pdf Size: 39 KB
Enclosed/attached please find the comments of the Promotion Martketing Association

Respectfully yours,
Edward Kabak

Submission Number: 00366

Received:2/18/2011 1:37:18 PM
Commenter: HeatherShaw
Organization:United States Council for International Business
State:New York
Attachments: 00366-57976.pdf Size: 34 KB    DOC: NOI_Commercial Data Privacy_1282011.pdf

 

Submission Number: 00367

Received:2/18/2011 1:57:09 PM
Commenter: MiriamWugmeister
Organization:Morrison & Foerster LLP
State:New York
Attachments: 00367-57979.pdf Size: 133 KB DoC: Commerce Privacy Report – GPA Comments – 2.pdf GPA Breach_Notification_Legislation_-_Key_Elements_to_Consider.pdf
Morrison & Foerster LLP on behalf of the Global Privacy Alliance (GPA) is pleased to offer the attached submission in response to the Federal Trade Commission’s request for comments on a Preliminary FTC Staff Report on “Protecting Consumer Privacy in an Era of Rapid Change: A Proposed Framework for Businesses and Policymakers.”

Submission Number: 00368

Received:2/18/2011 2:04:34 PM
Commenter: PrasadSharma
Organization:American Trucking Associations, Inc.
State:Virginia
Attachments: 00368-57984.pdf Size: 183 KB

Submission Number: 00369

Received:2/18/2011 2:05:18 PM
Commenter: Pameladixon
Organization:World Privacy Forum
State:California
Attachments: 00369-57987.pdf Size: 1476 KB    DoC: WPFComments_Commerce_fs_01282011.pdf
Attached please find the comments of the World Privacy Forum in PDF format. Please contact us at 760-470-2000 if there are any difficulties opening the file.

Sincerely,

Pam Dixon

Submission Number: 00371

Received:2/18/2011 2:10:29 PM
Commenter: JeffBloch
Organization:Consumer Bankers Association
State:Virginia
Attachments: 00371-57990.pdf Size: 45 KB
Please accept the attached comments from the Consumer Bankers Association in response to the FTC consumer privacy staff report. Thank you.

Sincerely,

Jeff Bloch

Submission Number: 00373

Received:2/18/2011 2:11:15 PM
Commenter: BrianRaymond
Organization:National Association of Manufacturers
State:District of Columbia
Attachments: 00373-57994.pdf Size: 194 KB

Submission Number: 00374

Received:2/18/2011 2:13:20 PM
Commenter: LaurenSholley
Organization:eBay
State:District of Columbia
Attachments: 00374-58001.pdf Size: 123 KB DoC: eBay Inc comments to DOC privacy green paper.pdf

 

Submission Number: 00375

Received:2/18/2011 2:15:38 PM
Commenter: AndreaWilliams
Organization:CTIA – The Wireless Association
State:District of Columbia
Attachments: 00375-58002.pdf Size: 102 KB DoC: Filed 2011-1-28 CTIA Letter to Dept of Commerce.pdf
Dear Mr. Secretary,

I respectfully submit these comments on behalf of CTIA – The Wireless Association® in response to the FTC Staff Preliminary Report on Protecting Consumer Privacy – File No. P095416.

Andrea D. Williams
Vice President of Law & Assistant General Counsel

CTIA – The Wireless Association®
1400 Sixteenth Street, NW
Suite 600
Washington, DC 20036
(202) 785-0081

Submission Number: 00376

Received:2/18/2011 2:20:23 PM
Commenter: PamDixon
Organization:World Privacy Forum
State:California
Attachments: 00376-58005.pdf Size: 1474 KB
Attached please find a second and final copy of our comments to the FTC. We have had some difficulties uploading our submission; we are sending this copy to ensure a good copy has been uploaded. Please contact us at 760-470-2000 if there are any difficulties opening this file.

Sincerely,

Pam Dixon

Submission Number: 00377

Received:2/18/2011 2:22:22 PM
Commenter: CameronLewis
Organization:Statz, Inc.
State:California
Attachments: 00377-58011.pdf Size: 100 KB
Statz commends the FTC staff for a forward-looking effort to adapt the agency’s historic privacy policies to the current commercial environment. Sea changes over the past three decades in industry data collection, use and sale have yet to be matched with comprehensive, effective business and legal protections for consumer privacy. The Report’s recommendation that a national United States privacy framework should apply to every entity that “collects or uses” data that can reasonably be linked to a specific consumer or device, including third parties, is a basic concept that unfortunately has yet to be accepted uniformly in the corporate milieu, especially traditional brick-and-mortar industries. As a result, the foundational principles articulated in the Report are destined to be viewed as an important landmark in the evolution of public policy on consumer privacy in this country.
Nonetheless, given the failure of a pure notice-and-choice privacy model to achieve the transparency and consent necessary for consumers to make informed decisions on whether and for what compensation (whether explicit or indirect) to release their private, digital data online – data which is unequivocally owned by consumers, not ISPs, vendors, content and service providers or third party data aggregators — Statz urges the FTC to move beyond the Report’s focus on transparency of data practices and their corollary, Fair Information Privacy Practices (FIPPs). There is no longer any valid distinction between digital privacy in the e-commerce and real-world settings. An increasingly interconnected “Internet of things” is collecting and transmitting an unparalleled amount of data on consumer behavior, consumption and product usage autonomously. The risk of consumer harm and deception in this emerging environment arises less from a lack of transparency and information security than from collection and transfer of data that the affected consumer never knows of and has no opportunity to consent to its usage and dissemination, let alone be compensated.
Statz and other firms are at present developing new business models for aggregation and sale of consumer data in transparent marketplaces that will monetize the private information consumers affirmatively decide they wish to sell. This will, for the first time, give individuals the ability to decide which personal information they want to release and the price at which they are willing to part with such commercially valuable data. We therefore concur with the Report’s conclusion that regulators should act cautiously about restricting the exchange and use of consumer data in order to “preserve the substantial consumer benefits made possible through the flow of information.” Given this appropriate caution and the simultaneous emergence of both ubiquitous data collection and transparent consumer data marketplace exchanges, the FTC should accordingly direct its privacy enforcement priorities to identifying and sanctioning companies that seek to expropriate consumer data rights by sale of consumer information, whether aggregated, de-identified or personally identifiable, without affirmative consent and some form of bartered-for compensation.
Statz believes a Commission enforcement focus on unfair and misleading practices by data mining firms that assert a right to use private data without explicit consent by and compensation to consumers is as significant to the development of privacy as the FTC’s traditional focus on unauthorized disclosure of such information and the Report’s recommendation of a “do-not-track” option for online, digital behavioral advertising. Personal data, which is being collected and sold today by third party companies with no notice no offer of compensation to consumers, is a concrete threat to consumer privacy at least as great as the length, ambiguity, arcane language and obscure location of online privacy notices to which the Report addresses the bulk of its analysis.

Submission Number: 00378

Received:2/18/2011 2:22:45 PM
Commenter: KendriaAlt
Organization:Sammuelson-Glushko Technology Law & Policy Clinic
State:Colorado
Attachments: 00378-58012.pdf Size: 238 KB
Please see the attached comments in response to the FTC’s preliminary staff report, Protecting Consumer Privacy in an Era of Rapid Change: A Proposed Framework for Businesses and Policymakers.

Please let me know if I may answer any questions you may have.

Submission Number: 00379

Received:2/18/2011 2:23:14 PM
Commenter: ValerieHayes
Organization:ACA International
State:Minnesota
Attachments: 00379-58014.pdf Size: 450 KB
Please see attached Comment.

Submission Number: 00380

Received:2/18/2011 2:25:05 PM
Commenter: KimberlyGray
Organization:IMS Health
State:Pennsylvania
Attachments: 00380-58015.pdf Size: 87 KB
Attached please find the comments of IMS Health as submitted by Kimberly Gray, CPO.

Submission Number: 00381

Received:2/18/2011 2:26:21 PM
Commenter: JohnDearie
Organization:Financial Services Forum
State:District of Columbia
Attachments: 00381-58016.pdf Size: 106 KB DoC: FinancialServicesForum.pdf

 

Submission Number: 00382

Received:2/18/2011 2:27:02 PM
Commenter: GuyMeiron
Organization:Fugro Horizons Inc.
State:South Dakota
I respectfully urge the FTC not to implement any enforcement or broad regulation that would have a harmful affect on firms like Fugro Horizons Inc. in the broad private geospatial community. Specifically, the FTC report imprecisely uses and regulates the term “precise geolocation information” or “precise geolocation data”. This would adversely impact consumers, geospatial firms, and government programs. My firm is particularly concerned that this term was not defined in the FTC staff report and the proposed regulations will have broad and harmful unintended consequences. The use of the term “geolocation” or other geospatial relevant terminology that appear in the FTC regulations will impose a significant new liability on my firm. It regulates areas of the economy and geospatial activities that have not been identified as a problem or pose any privacy concern to citizens. The regulations could thwart common, legitimate, and emerging uses of geospatial data for emergency response/post disaster remediation, insurance, environmental protection, E-911 & ambulance services, fleet management broadband mapping, home security, navigation, mortgage foreclosure monitoring/early warning system, and others.
Moreover, activities, technologies, and applications development could be deemed illegal. For example, it would be impractical, if not impossible, for my firm to obtain prior approval or consent from individual citizens prior to acquiring or applying data such as satellite imagery, aerial photography, or parcel, address, or
transportation data. The FTC regulation would effectively ban my firm, or our clients, from important value added, integration and application activities. Finally, any such FTC regulation could put U.S. companies at a significant and insurmountable competitive
disadvantage against foreign firms that may not be covered by that regulation, or for which enforcement would be impractical. FTC should provide the necessary and desirable privacy protections to individual citizens; however, it should not limit the geospatial community’s ability to grow, prosper, and bring to the market those technologies and applications that meet the economic demands of consumers and citizens.

Submission Number: 00383

Received:2/18/2011 2:29:51 PM
Commenter: PaulBoyle
Organization:Newspaper Association of America
State:Virginia
Attachments: 00383-58017.pdf Size: 121 KB

Submission Number: 00385

Received:2/18/2011 2:30:36 PM
Commenter: MichaelFertik
Organization:Reputation.com, Inc.
State:California
Attachments: 00385-58030.pdf Size: 132 KB DoC: Comments of Reputation.com Inc to the Department of Commerce-20110128.pdf
Please see the attached comment from Reputation.com, Inc., calling for a full reboot of online consumer privacy. The same comment is attached in PDF (print) and HTML (web) formats for the convenience of online and offline readers.

Please feel free to contact us with any questions or for additional comment. Thank you.

Reputation.com, Inc.
2688 Middlefield Road, Bldg C
Redwood City, CA 94064
(877) 720-6488
pr@reputationdefender.com

Submission Number: 00386

Received:2/18/2011 2:33:43 PM
Commenter: MarcRotenberg
Organization:Electronic Privacy Information Center
State:District of Columbia
Attachments: 00386-58031.pdf Size: 213 KB DoC: Electronic Privacy Information Center (EPIC) | Electronic Privacy Information Center (EPIC)

 

Submission Number: 00387

Received:2/18/2011 2:37:43 PM
Commenter: DougJohnson
Organization:American Bankers Association
State:District of Columbia
Attachments: 00387-58034.pdf Size: 412 KB
The American Bankers Association is pleased to provide the attached comments regarding FTC’s Staff Report on “Protecting Consumer Privacy in an Era of Rapid Change: A Proposed Framework for Businesses and Policymakers.”

Submission Number: 00388

Received:2/18/2011 2:38:08 PM
Commenter: MikeZaneis
Organization:Interactive Advertising Bureau
State:District of Columbia
Attachments: 00388-58037.pdf Size: 4642 KB DoC: IAB’s Comments to DoC.pdf
Attached are the comments of the Interactive Advertising Bureau.

Submission Number: 00389

Received:2/18/2011 2:40:15 PM
Commenter: Robert Holleyman
Organization:Business Software Alliance
State:District of Columbia
Attachments: 00389-58040.pdf Size: 4923 KB DoC: BSA Comments on Commerce Privacy Framework 01.28.11.pdf

 

Submission Number: 00390

Received:2/18/2011 2:44:23 PM
Commenter: CySmith
Organization:Coalition of Geospatial Organizations
State:Oregon
Attachments: 00390-58043.pdf Size: 171 KB
The Coalition of Geospatial Organizations has serious concerns about the preliminary staff report, as contained in our attached letter.

Submission Number: 00391

Received:2/18/2011 2:44:59 PM
Commenter: ScottMeyer
Organization:Evidon
State:New York
Attachments: 00391-58045.pdf Size: 255 KB
Please accept the attached comment on behalf of Evidon.

Submission Number: 00392

Received:2/18/2011 2:46:18 PM
Commenter: NualaO’Connor kelly
Organization:General Electric
State:Connecticut
Attachments: 00392-58047.pdf Size: 70 KB DoC: GE comment letter.pdf
It is my pleasure to submit these comments on behalf of the General Electric Company, in support of the work of the Federal Trade Commission on responsible privacy practices.

Humbly submitted,

Nuala O’Connor Kelly
CPO
GE

Submission Number: 00393

Received:2/18/2011 2:48:00 PM
Commenter: DanielWalden
Organization:Medco Health Solutions
State:New Jersey
Attachments: 00393-58048.pdf Size: 52 KB

Submission Number: 00395

Received:2/18/2011 2:52:29 PM
Commenter: MichaelHintze
Organization:Microsoft Corporation
State:Washington
Attachments: 00395.pdf Size: 792 KB DoC: Microsoft Comments on Commerce Privacy Green Paper – final.pdf
Please find attached the comments from Microsoft Corporation on the
Preliminary FTC Staff Report on “Protecting Consumer Privacy in an Era of Rapid Change: A Proposed Framework for Businesses and Policymakers.”

Thank you very much for the opportunity to participate in this important dialogue.

Submission Number: 00396

Received:2/18/2011 2:53:44 PM
Commenter: SanjayParthasarathy
Organization:Honeywell International
State:District of Columbia
Attachments: 00396-58053.pdf Size: 67 KB

Submission Number: 00397

Received:2/18/2011 2:58:10 PM
Commenter: OmarTawakol
Organization:BlueKai
State:California
Attachments: 00397-58054.pdf Size: 59 KB    DoC: Bluekai.PDF

 

Submission Number: 00398

Received:2/18/2011 3:00:26 PM
Commenter: Tony Hadley
Organization:Experian
State:District of Columbia
Attachments: 00398-58063.pdf Size: 131 KB
00398-58064.pdf Size: 112 KB     DoC: Experian.PDF

 

Submission Number: 00399

Received:2/18/2011 3:00:41 PM
Commenter: MichaelSignorelli
Organization:Coalition of Trade Associations
State:District of Columbia
Attachments: 00399-58070.pdf Size: 117 KB DoC: Industry Comment to DoC.pdf
Attached are comments from a coalition of trade associations including: American Advertising Federation American, Association of Advertising Agencies, ASAE, Association of National Advertisers, Coalition for Healthcare Communication, Consumer Data Industry Association, Direct Marketing Association, Electronic Retailing Association, Interactive Advertising Bureau, National Business Coalition on E-Commerce and Privacy, NetChoice, Performance Marketing Association, and U.S. Chamber of Commerce.

Submission Number: 00400

Received:2/18/2011 3:03:34 PM
Commenter: LoraineReitman
Organization:Electronic Foundation
State:California
Attachments: 00400-58074.pdf Size: 398 KB DoC: EFF_Comments_to_Commerce.pdf EFF_Comments_to_Commerce_Exhibit_1_of_1.pdf

 

 

Submission Number: 00401

Received:2/18/2011 3:04:19 PM
Commenter: KellyBroder
Organization:Surescripts, LLC
State:Virginia
Attachments: 00401-58076.pdf Size: 236 KB
We thank you for the opportunity to comment in response to the FTC’s preliminary staff report. Please see our comments attached hereto.

Submission Number: 00402

Received:2/18/2011 3:05:31 PM
Commenter: JohnSimpson
Organization:Consumer Watchdog
State:California
Attachments: 00402-58080.pdf Size: 268 KB DoC: Consumer Watchdog.pdf
Dear Sir or Madam,

Attached as a PDF file please find Consumer Watchdog’s comments on The Federal Trade Commission’s recent report “Protecting Consumer Privacy in an Era of Rapid Change: A Proposed Framework for Businesses and Policymakers.”

Consumer Watchdog calls on the Federal Trade Commission to create a “Do Not Track Me” mechanism to protect consumers’ online privacy and believes that such a mechanism must have the force of law behind it.

Thank you for your consideration.

Sincerely,
John M. Simpson
Consumer advocate

Consumer Watchdog
1750 Ocean Park Blvd., Suite 200
Santa Monica, CA
90405

Submission Number: 00403

Received:2/18/2011 3:05:58 PM
Commenter: JackFarrell
Organization:Avery Dennison RFID Company
State:Georgia
Attachments: 00403-58083.pdf Size: 892 KB
Please see the attached letter, filed on behalf of Avery Dennison, commenting on the Preliminary FTC Staff Report entitled “Protecting Consumer Privacy in an Era of Rapid Change.” Thank you.

Submission Number: 00404

Received:2/18/2011 3:06:17 PM
Commenter: ChristopherWilson
Organization:TechAmerica
State:District of Columbia
Attachments: 00404-58081.pdf Size: 543 KB DoC: TechAmericaResponsetoDOCPrivacyGreenPaper.pdf

 

Submission Number: 00405

Received:2/18/2011 3:15:37 PM
Commenter: HowardFienberg
Organization:Marketing Research Association (MRA)
State:District of Columbia
Attachments: 00405-58079.pdf Size: 207 KB DoC: MRA_comments_DOC_privacy_1-28-11.pdf
The Marketing Research Association (MRA) hereby submits these comments in response to the “Preliminary FTC Staff Report on Protecting Consumer Privacy in an Era of Rapid Change: A Proposed Framework for Businesses and Policymakers” (“the Report”).

Submission Number: 00406

Received:2/18/2011 3:17:58 PM
Commenter: Provost
State:New York
Attachments: 00406-58078.pdf Size: 212 KB

Submission Number: 00407

Received:2/18/2011 3:18:12 PM
Commenter: Deborah Pierce
Organization:PrivacyActivism
State:California
Attachments: 00407-58077.pdf Size: 98 KB
Please see our attached comments.

Submission Number: 00408

Received:2/18/2011 3:19:15 PM
Commenter: Massey & Tobin
Organization:UnitedHealth Group
State:Minnesota
Attachments: 00408-58075.pdf Size: 188 KB DoC: UnitedHealth Group Commerce Green Paper Comment Letter 01.28.2011.pdf
On behalf of UnitedHealth Group, attached please find our comment letter to Federal Trade Commission’s Preliminary Staff Report entitled “Protecting Consumer Privacy in an Era of Rapid Change.”

Should you have any questions regarding out suggestions, please do not hesitate to contact me.

Submission Number: 00409

Received:2/18/2011 3:23:41 PM
Commenter: StephenPhipps
Organization:Woolpert, Inc.
State:Ohio
I urge the FTC not to implement a broad regulation that would have a harmful affect on firms like mine in the broad private geospatial community. The current FTC draft language uses the terms “precise geolocation information” or “precise geolocation data”. This would adversely impact consumers, geospatial firms, and government
programs. My firm is particularly concerned that this term was not defined in the FTC staff report and the
proposed regulations will have broad and harmful unintended consequences.

The use of the term “geolocation” or other geospatial relevant terminology that appear in the FTC regulations
will impose a significant new liability on my firm. It regulates areas of the economy and geospatial activities
that have not been identified as a problem or pose any privacy concern to citizens.

The regulations would limit common, legitimate, and emerging uses of geospatial data for emergency
response/post disaster remediation, insurance, environmental protection, E-911 & ambulance services, fleet
management broadband mapping, home security, navigation, mortgage foreclosure monitoring/early warning
system, and others.

Activities, technologies, and applications development would be deemed illegal. For example, it
would be impractical, if not impossible, for my firm to obtain prior approval or consent from individual citizens
prior to acquiring or applying data such as satellite imagery, aerial photography, or parcel, address, or
transportation data. The FTC regulation would effectively ban my firm, or our clients, from important value-added,
integration and application activities.

Please reconsider this broad reaching regulation.

Submission Number: 00410

Received:2/18/2011 3:23:58 PM
Commenter: MichaelSignorelli
Organization:4As, AAF, ANA, DMA, & IAB
State:District of Columbia
Attachments: 00410-58073.pdf Size: 70 KB DoC: Coalition Comments to DoC.pdf
Attached are comments from the 4As, AAF, ANA, DMA, and IAB concerning the Self-Regulatory Program for Online Behavioral Advertising.

Submission Number: 00411

Received:2/18/2011 3:26:28 PM
Commenter: KevinRupy
Organization:USTelecom
State:District of Columbia
Attachments: 00411-58072.pdf Size: 48 KB

Submission Number: 00412

Received:2/18/2011 3:28:04 PM
Commenter: JoeWeir
Organization:Belo Corp.
State:Texas
Attachments: 00412-58071.pdf Size: 245 KB

Submission Number: 00413

Received:2/18/2011 3:29:15 PM
Commenter: MichaelRichter
Organization:Facebook, Inc.
State:California
Attachments: 00413-58069.pdf Size: 1435 KB DoC: Facebook’s Response to DoC.pdf

 

Submission Number: 00414

Received:2/18/2011 3:33:33 PM
Commenter: RebeccaMadigan
Organization:Performance Marketing Association
State:California
Attachments: 00414-58068.pdf Size: 153 KB
Please find attached our organization’s response to A Preliminary FTC Staff Report on “Protecting Consumer Privacy in an Era of Rapid Change: A Proposed Framework for Businesses and Policymakers”

Thank you for the opportunity for industry members to respond to your report.

Submission Number: 00415

Received:2/18/2011 3:44:33 PM
Commenter: KatherineHahn
Organization:SAS
State:Virginia
Attachments: 00415-58067.pdf Size: 112 KB

Submission Number: 00416

Received:2/18/2011 3:45:50 PM
Commenter: StacieBehler
Organization:Meijer
State:Michigan
Attachments: 00416-58066.pdf Size: 1024 KB

Submission Number: 00417

Received:2/18/2011 3:46:47 PM
Commenter: PabloChavez
Organization:Google Inc.
State:District of Columbia
Attachments: 00417-58065.pdf Size: 244 KB DoC: FINALCommentsonDepartmentofCommercePrivacyGreenPaper (3).pdf

 

Submission Number: 00418

Received:2/18/2011 3:53:02 PM
Commenter: RussellFrisby
Organization:Edison Electric Institute
State:District of Columbia
Attachments: 00418-58062.pdf Size: 255 KB
Preliminary FTC Staff Report: Protecting Consumer Privacy in an Era of Rapid Change: A Proposed Framework for Business and Policymakers

Submission Number: 00419

Received:2/18/2011 3:56:24 PM
Commenter: MalloryDuncan
Organization:National Retail Federation
State:District of Columbia
Attachments: 00419-58061.pdf Size: 115 KB

Submission Number: 00420

Received:2/18/2011 3:59:12 PM
Commenter: KeithKrom
Organization:AT&T Inc.
State:District of Columbia
Attachments: 00420-58058.pdf Size: 97 KB DoC: ATT Commerce Comments 1-28-11FINAL.pdf
00420-58059.pdf Size: 326 KB
00420-58060.pdf Size: 319 KB
As noted in Transmittal letter

Submission Number: 00421

Received:2/18/2011 3:59:13 PM
Commenter: RobertBeizer
Organization:Gray Television, Inc.
State:District of Columbia
Attachments: 00421-58057.pdf Size: 452 KB

Submission Number: 00424

Received:2/18/2011 4:02:55 PM
Commenter: HamiltonDavison
Organization:American Catalog Mailers Association
State:New York
Attachments: 00424-58052.pdf Size: 272 KB DoC: ACMA Comments to DOC Report.pdf
pdf attached

Submission Number: 00425

Received:2/18/2011 4:03:22 PM
Commenter: ChristopherCalabrese
Organization:American Civil Liberties Union
State:District of Columbia
Attachments: 00425-58049.pdf Size: 154 KB DoC: Final Commerce Comments January 2011 on DNT.pdf
Do Not Track: A Fundamental Civil Liberties Protection for the 21st Century

Submission Number: 00427

Received:2/18/2011 4:08:25 PM
Commenter: SheilaMillar
Organization:Keller and Heckman LLP
State:District of Columbia
Attachments: 00427-58046.pdf Size: 167 KB DoC: Response to DOC_KH.pdf
Attached please find comments on behalf of the Toy Industry Association on the FTC’s Preliminary Staff Report, Protecting Consumer Privacy in an Era of Rapid Change, December, 2010.

Submission Number: 00428

Received:2/18/2011 4:08:31 PM
Commenter: JamellahEllis
Organization:Verizon
State:Virginia
Attachments: 00428-58044.pdf Size: 156 KB DoC: 01 28 11 Verizon, Verizon Wireless Comments NTIA Privacy NOI.pdf
Please see the attached comments from Verizon and Verizon Wireless. Thank you.

Submission Number: 00429

Received:2/18/2011 4:08:54 PM
Commenter: MarthaCoakley
Organization:Massachusetts Office of the Attorney General
State:Massachusetts
Attachments: 00429-58042.pdf Size: 531 KB

Submission Number: 00430

Received:2/18/2011 4:13:49 PM
Commenter: StevenManzo
Organization:Reed Elsevier Inc.
State:District of Columbia
Attachments: 00430-58041.pdf Size: 128 KB DoC: Reed Elsevier Comments to Department of Commerce.pdf
On behalf of Reed Elsevier Inc., we provide the attached comments in response to the Commission’s request for comments on “Protecting Consumer Privacy in an Era of Rapid Change: A Proposed Framework for Businesses and Policymakers.”

Submission Number: 00431

Received:2/18/2011 4:22:40 PM
Commenter: DavidBruggeman
Organization:U.S. Public Policy Council, Association for Computing Machinery
State:District of Columbia
Attachments: 00431-58039.pdf Size: 290 KB DoC: Commerce_Department_Online_Privacy_Comments_USACM.pdf
Attached please find the comments from the U.S. Public Policy Council of the Association for Computing Machinery in response to the FTC preliminary staff report “Protecting Consumer Privacy in an Era of Rapid Change: A Proposed Framework for Businesses and Policymakers.” If you have any questions or need additional information, please contact our Director of Public Policy, Cameron Wilson, at 202-659-9711.

Submission Number: 00432

Received:2/18/2011 4:25:50 PM
Commenter: RickChessen
Organization:National Cable & Telecommunications Association
State:District of Columbia
Attachments: 00432-58038.pdf Size: 192 KB DoC: 012811 Commerce Privacy Comments.pdf
Attached are comments by the National Cable & Telecommunications Association in File No. P095416 [A Preliminary FTC Staff Report on “Protecting Consumer Privacy in an Era of Rapid Change}

Submission Number: 00433

Received:2/18/2011 4:25:50 PM
Commenter: ChristinaPeters
Organization:IBM
State:New York
Attachments: 00433-58036.pdf Size: 74 KB DoC: image2011-01-28-165552.pdf
Please find IBM’s comments in the attached.

Submission Number: 00434

Received:2/18/2011 4:26:22 PM
Commenter: RossSchulman
Organization:Computer and Communications Industry Association
State:District of Columbia
Attachments: 00434-58035.pdf Size: 157 KB DoC: CCIA Commerce Comments.pdf

 

Submission Number: 00435

Received:2/18/2011 4:34:25 PM
Commenter: DavidLeDuc
Organization:Software & Information Industry Association
State:District of Columbia
Attachments: 00435-58033.pdf Size: 240 KB DoC: SIIA_DOC-Privacy&Innovation_28Jan2011.pdf

 

Submission Number: 00436

Received:2/18/2011 4:37:56 PM
Commenter: MarkBrooks
Organization:Aeroquest Optimal, Inc
State:Alabama
Attachments: 00436-58032.pdf Size: 127 KB
Please find attached Aeroquest Optimal’s response to the December 1, 2010, Federal Trade Commission (FTC) report, “Protecting Consumer Privacy in an Era of Rapid Change.”

Submission Number: 00437

Received:2/18/2011 4:38:47 PM
Commenter: DavidBruggeman
Organization:U.S. Public Policy Council of the Association for Computing Machinery
State:District of Columbia
Attachments: 00437-58029.pdf Size: 290 KB DoC: (duplicate) Commerce_Department_Online_Privacy_Comments_USACM.pdf
Attached please find the comments of the U.S. Public Policy Council of the Association for Computing Machinery in response to the Preliminary Staff Report “Protecting Consumer Privacy in an Era of Rapid Change: A Proposed Framework for Businesses and Policymakers.” If you have any questions or need additional information, please contact us at 202-659-9711, or email our Director of Public Policy, Cameron Wilson, at cameron.wilson@acm.org

Submission Number: 00438

Received:2/18/2011 4:55:47 PM
Commenter: Cy Smith
Organization:AirSage, Inc.
State:Georgia
Attachments: 00438-58027.pdf Size: 59 KB
Mr. Secretary,

I respectfully submit these comments on behalf of AirSage, Inc. in response to FTC Staff Preliminary Report on Protecting Consumer Privacy – File No. P095416.

Sincerely,
Cy Smith
Founder and President
AirSage, Inc.
400 Embassy Row NE Suite 100

Submission Number: 00439

Received:2/18/2011 4:59:50 PM
Commenter: ElizabethBoard
Organization:GS1
State:District of Columbia
Attachments: 00439-58026.pdf Size: 143 KB DoC: GS1 Comments – DOC Docket No. 101214614-0614-01.pdf
Attached you will find GS1’s comments to the Federal Trade Commission Preliminary Staff Report “Protecting Consumer Privacy in an Era of Rapid Change: A Proposed Framework for Businesses and Policymakers.”

Submission Number: 00440

Received:2/18/2011 5:00:49 PM
Commenter: ALAN CHAPELL
Organization:CHAPELL & ASSOCIATES
State:New York
Attachments: 00440-58025.pdf Size: 116 KB

Submission Number: 00441

Received:2/18/2011 5:02:30 PM
Commenter: ErikLieberman
Organization:Food Marketing Institute
State:Virginia
Attachments: 00441-58024.pdf Size: 107 KB

Submission Number: 00442

Received:2/18/2011 5:05:05 PM
Commenter: MattEmery
Organization:Quicken Loans
State:Michigan
Attachments: 00442-58023.pdf Size: 121 KB DoC: Quicken Loans’s Comments on the Department of Commerce’s Internet Policy Taskforce’s Report.pdf
Please find our comments attached.

Submission Number: 00443

Received:2/18/2011 5:05:10 PM
Commenter: StephenWu
Organization:American Bar Association Section of Science and Technology
State:Illinois
Attachments: 00443-58022.pdf Size: 374 KB

Submission Number: 00444

Received:2/18/2011 5:09:44 PM
Commenter: AnneToth
Organization:Yahoo! Inc.
State:California
Attachments: 00444-58021.pdf Size: 353 KB DoC: DOC comments 01282011_yahoo.pdf
Yahoo! Inc. comments on the Preliminary Staff Report on Protecting Consumer Privacy in an Era of Rapid Change.

Submission Number: 00445

Received:2/18/2011 5:39:09 PM
Commenter: Thomas Boyd
Organization:National Business Coalition on E-Commerce and Privacy
State:District of Columbia
Attachments: 00445-58020.pdf Size: 7473 KB DoC: Comments of the NBC.pdf

 

Submission Number: 00446

Received:2/18/2011 5:40:41 PM
Commenter: LindseyTonsager
Organization:Covington & Burling LLP
State:District of Columbia
Attachments: 00446-58019.pdf Size: 251 KB

Submission Number: 00447

Received:2/18/2011 5:41:33 PM
Commenter: JimHalpert
Organization:Internet Commerce Coalition
State:District of Columbia
Attachments: 00447-58018.pdf Size: 147 KB DoC: ICC – Green Paper Comments (01-28-2011)(final).pdf

 

Submission Number: 00448

Received:2/18/2011 5:42:56 PM
Commenter: DanielCastro
Organization:Information Technology and Innovation Foundation
State:District of Columbia
Attachments: 00448-58013.pdf Size: 232 KB    DoC: 2011-Privacy-and-Innovation-Comments-Final.pdf

 

Submission Number: 00449

Received:2/18/2011 5:48:31 PM
Commenter: LindaWoolley
Organization:Direct Marketing Association, Inc.
State:District of Columbia
Attachments: 00449-58009.pdf Size: 213 KB
00449-58010.pdf Size: 574 KB DoC: DMA Comments.pdf
On behalf of the Direct Marketing Association, Inc., we provide the attached comments in response to the Commission’s request for comments on “Protecting Consumer Privacy in an Era of Rapid Change: A Proposed Framework for Businesses and Policymakers.”

Submission Number: 00450

Received:2/18/2011 5:53:39 PM
Commenter: FranMaier
Organization:TRUSTe
State:California
Attachments: 00450-58008.pdf Size: 703 KB DoC: DoC Green Paper Comments (20110128)-Signed.pdf
TRUSTe’s comments are attached. Thank you for the opportunity to share our views.

Submission Number: 00451

Received:2/18/2011 5:54:41 PM
Commenter: BerinSzoka
Organization:TechFreedom
State:District of Columbia
Attachments: 00451-58007.pdf Size: 618 KB

Submission Number: 00452

Received:2/18/2011 6:18:43 PM
Commenter: WilliamKovacs
Organization:U.S. Chamber of Commerce
State:District of Columbia
Attachments: 00452-58006.pdf Size: 99 KB DoC: U.S. Chamber — Comments on DoC Privacy Green Paper.pdf
The U.S. Chamber of Commerce is pleased to submit these comments to the Federal Trade Commission in response to the agency’s request for comments on the Preliminary FTC Staff Report on Protecting Consumer Privacy in an Era of Rapid Change: A Proposed Framework for Businesses and Policymakers.

Submission Number: 00453

Received:2/18/2011 6:25:54 PM
Commenter: LorrieCranor
Organization:Carnegie Mellon University
State:Pennsylvania
Attachments: 00453-58003.pdf Size: 470 KB
00453-58004.pdf Size: 508 KB
Attached please find my comments and the paper Token Attempt: The Misrepresentation of Website Privacy Policies through the Misuse of P3P Compact Policy Tokens

Submission Number: 00454

Received:2/18/2011 6:26:19 PM
Commenter: HarlanYu
State:New Jersey
Attachments: 00454-58000.pdf Size: 129 KB

Submission Number: 00455

Received:2/18/2011 6:37:20 PM
Commenter: JimBrock
Organization:PrivacyChoice
State:California
Attachments: 00455-57999.pdf Size: 555 KB
Please see comments in the attached PDF.

Submission Number: 00456

Received:2/18/2011 6:38:46 PM
Commenter: JoshLemieux
Organization:The Markle Foundation
State:New York
Attachments: 00456-57998.pdf Size: 181 KB DoC: 20110218-Dept-of-Commerce-Collab-Cmts.pdf
These comments represent a collective view that was deeply informed by the many and diverse collaborators of Markle Connecting for Health. Please see attached letter.

Submission Number: 00457

Received:2/18/2011 6:54:19 PM
Commenter: AlanSimpson
Organization:Common Sense Media
State:California
Attachments: 00457-57995.pdf Size: 422 KB
00457-57996.pdf Size: 150 KB
00457-57997.pdf Size: 254 KB
Common Sense Media’s comments on protecting consumer privacy — especially for kids and teens — in an era of rapid change.

Submission Number: 00458

Received:2/18/2011 6:56:02 PM
Commenter: Dhar, Hsieh, Sundararajan
Organization:New York University
State:New York
Attachments: 00458-57993.pdf Size: 134 KB
Vasant Dhar , Jessy Hsieh , Arun Sundararajan

The purpose of this document is to respond to selected questions for comment on the proposed framework in the FTC report “Protecting Consumer Privacy in an Era of Rapid Change: A Proposed Framework for Businesses and Policymakers” (December 1st, 2010). Our responses are based on our ongoing research about online privacy and data risk at NYU Stern School’s Center for Digital Economy Research. Our findings are described further in Dhar, Hsieh and Sundararajan (2011).

The specific questions proposed for comment that our response relates to are:

1. Are there practices that should be considered “commonly accepted” in some business contexts but not others?
2. Under what circumstances (if any) is it appropriate to offer choice as a “take it or leave it” proposition, whereby a consumer’s use of a website, product, or service constitutes consent to the company’s information practices?
3. What types of disclosures and consent mechanisms would be most effective to inform consumers about the trade-offs they make when they share their data in exchange for services?
4. Should access to data differ for consumer-facing and non-consumer facing entities?
5. Should consumers receive notice when data about them has been used to deny them benefits? How should such notice be provided? What are the costs and benefits of providing such disclosure?

Summary and key points
— There is privacy risk inherent in any form of consumer data acquisition, retention and use by a firm. Some parts of this risk are non-systemic and can be reduced by firm and/or policy action, while other parts are systemic and cannot be altered without widespread changes in social norms.
— Our framework for examining the non-systemic privacy risk associated with the acquisition, retention and use of consumer data is based on the relative extent to which the acquiring party (typically a firm or government) and the providing party (typically a consumer) perceive that they own the data in question, which in turn is based on the intention of the consumer.
— Much like intellectual property, data is non-rival, and in the absence of appropriate technological or legal controls, is non-excludable. Any assessment of ownership must be based on some notion of the division of rights between a data provider (consumer) and a data acquirer (firm).
— Currently, both the data acquirer and the data provider seem to have equal and comprehensive rights over the exchanged data (in principle) independent of the context of data exchange. By default, this status quo gives excessive ownership rights to the acquirer (the firm) and generates excessive non-systemic data risk for both parties.
— Consumer perception of data ownership is associated with the intent of the consumer when transferring data to the firm. Specifically, the consumer inherently presumes a lower granting of rights to the firm if the consumer did not intend to transfer the data in exchange for a service by the firm.
— Our framework for classifying consumer intent during data transfer identifies two dimensions that can be used to assess perceived ownership: whether the data transfer was explicit or implicit, and whether the data transfer was voluntary or required for service provision.
— Specifying the intent associated with consumer data transfer on the Internet is complex because some kind of data transfer is necessary for every action during an electronic interaction, irrespective of whether the action explicitly involved intentional data transfer. This is because a consumer may be unaware that data not core to the interaction are being transferred.
— The distinction between explicit and implicit data transfer can be partially disambiguated by examining the corresponding actions that would need to be taken by the firm and the consumer if such a transfer was occurring in a non-electronic

Submission Number: 00459

Received:2/18/2011 7:01:38 PM
Commenter: ReggieDavis
Organization:Zynga Inc.
State:California
Attachments: 00459-57992.pdf Size: 2220 KB

Submission Number: 00461

Received:2/18/2011 7:35:33 PM
Commenter: ChristopherSoghoian
Organization:Center for Applied Cybersecurity, Indiana University
State:District of Columbia
Attachments: 00461-57989.pdf Size: 205 KB
My previously submitted comment (#00460) had a few typos that I missed.
Please remove that one, and accept this one for the record.

Thanks

Submission Number: 00463

Received:2/18/2011 8:25:59 PM
Commenter: JanStieger
Organization:DBA International
State:Virginia
Attachments: 00463-57985.pdf Size: 109 KB

Submission Number: 00464

Received:2/18/2011 9:06:46 PM
Commenter: MichaelHonchar
State:Missouri
Attachments: 00464-57983.pdf Size: 16 KB
“HONCHAR COMMENT PRIVACY 1-18-11.doc” attached

Submission Number: 00465

Received:2/18/2011 9:13:55 PM
Commenter: AshleyGoren
Organization:Genetic Alliance
State:District of Columbia
Attachments: 00465-57982.pdf Size: 215 KB
Genetic Alliance, a non-profit health advocacy organization committed to transforming health through genetics, supports the comments submitted by Wolters Kluwer Pharma Solutions. Genetic Alliance believes that patient de-identified prescription data sets that comply with the Health Insurance Portability and Accountability Act (HIPAA) serve crucial roles in improving health care. De-identified prescription data sets provide instrumental information to researchers, public health organizations, government agencies, and pharmaceutical companies. They are used to expedite the development and improvement of pharmaceuticals, facilitate medication quality and cost effectiveness review, assist in detecting adverse drug reactions, and aid in identifying and responding to infectious outbreaks. HIPAA imposes stringent standards for de-identification that were carefully designed to protect patients’ privacy while recognizing the societal interests of properly de-identified data. Based on HIPAA’s rigorous privacy standards and the numerous benefits that come from this information, we urge the FTC to expressly exclude HIPAA de-identified data from any consumer privacy protection framework.

Submission Number: 00466

Received:2/18/2011 9:21:59 PM
Commenter: PeterBlenkinsop
Organization:International Pharmaceutical Privacy Consortium
State:District of Columbia
Attachments: 00466-57981.pdf Size: 266 KB DoC: IPPC Comments January 2011.pdf
Dear Sir/Madam,

On behalf of the International Pharmaceutical Privacy Consortium (IPPC), I am pleased to submit these comments on the FTC Staff Report on “Protecting Consumer Privacy in an Era of Rapid Change: A Proposed Framework for Businesses and Policymakers.”

Thank you for your consideration.

Sincerely,

Peter Blenkinsop

Submission Number: 00467

Received:2/18/2011 9:25:11 PM
Commenter: JonathanMayer
Organization:Stanford Security Laboratory
State:California
Attachments: 00467-57980.pdf Size: 274 KB
Please find attached our comment in PDF format.

Submission Number: 00468

Received:2/18/2011 9:55:43 PM
Commenter: JohnRoam
State:District of Columbia
Dear FTC,

Isn’t it possible that if “Do Not Track” were implemented too heavy-handedly, or too unilaterally without nuance or regard to genuine non-advertising purposes, it could risk damaging the mechanisms of valuable e-commerce, such as online transactions, affiliate sales, and the like?

We must tread carefully here lest the baby be thrown out with the bathwater… Or put another way, not kill the golden goose in seeking a remedy for the bad actors in one segment.

Thank you and sincerely yours,

John Roam
Washington, D.C.

Submission Number: 00469

Received:2/18/2011 10:25:28 PM
Commenter: JustinBrookman
Organization:Center for Democracy & Technology
State:District of Columbia
Attachments: 00469-57977.pdf Size: 501 KB
00469-57978.pdf Size: 285 KB DoC: CDT privacy comments.pdf
Attached please find the comments of the Center for Democracy & Technology in response to the Preliminary FTC Staff Report on “Protecting Consumer Privacy in an Era of Rapid Change: A Proposed Framework for Businesses and Policymakers.”

Submission Number: 00470

Received:2/18/2011 10:56:10 PM
Commenter: KatherineJohnson
Organization:Patient Privacy Rights
State:Texas
Attachments: 00470-57975.pdf Size: 165 KB
Please see the attached comments. We included comments as a word document and as a PDF.

Patient Privacy Rights is the leading consumer voice for building ethical, trustworthy health IT systems. We have over 12,000 members and lead the bipartisan Coalition for Patient Privacy, representing 10.3 million Americans. We seek to restore the right to informed consent, and the right to health information privacy in electronic systems. Individual consent and control are imperative for patients and consumers to willingly participate in electronic systems and data exchanges.

Submission Number: 00472

Received:2/18/2011 11:15:28 PM
Commenter: Hamlin, KaliyaHodder, Mary
Organization:Personal Data Ecosystem Consortium
State:California
Attachments: 00472-57974.pdf Size: 1124 KB DoC: DOCGreenPaperLetterQandAfromPDE.pdf
Thank you very much for allowing us to submit our response to the FTC’s White Paper on Do Not Track. Our letter and Q&A are both in the same document.

Sincerely,
Mary Hodder

PS.. we did have some issues submitting this before the end of the day on 2/18 on your website.. so we made several attempts.

Submission Number: 00473

Received:2/23/2011
Commenter: ChuckTeller
Organization:Catalog Choice
State:California
Attachments: 00473.1.pdf Size: 278 KB
00473.2.pdf Size: 3742 KB
00473.3.pdf Size: 11 KB DoC: DOC Green Paper Comments-Catalog Choice.pdf

 

Submission Number: 00474

Received:2/23/2011
Commenter: DemetriosEleftheriou
Organization:EMC Corporation
State:Massachusetts
Attachments: 00474.pdf Size: 46 KB

Submission Number: 00476

Received:2/18/2011 10:44:30 AM
Commenter: BarryCutler
Organization:Electronic Retailing Association
State:
Attachments: 00476-58099.pdf Size: 1424 KB

Submission Number: 00477

Received:2/18/2011 10:49:31 AM
Commenter: JeffreyFrancer
Organization:PhRMA
State:
Attachments: 00477-58101.pdf Size: 1407 KB

Submission Number: 00478

Received:2/23/2011
Commenter:
Organization:DBA International
State:
Attachments: 00478-58104.pdf Size: 111 KB

Submission Number: 00479

Received:2/23/2011
Commenter: JohnGingrich
Organization:Department of Veterans Affairs
State:
Attachments: 00479-58107.pdf Size: 696 KB
00479-58108.pdf Size: 655 KB

Submission Number: 00480

Received:2/23/2011
Commenter: AlexanderFowler
Organization:Mozilla
State:
Attachments: 00480-58110.pdf Size: 1031 KB

Submission Number: 00481

Received:2/21/2011
Commenter: TomChernaik
Organization:CMPLY, Inc.
State:
Attachments: 00481-58112.pdf Size: 392 KB    DoC: CMPLY NTIA Comment.pdf

 

Submission Number: 00482

Received:2/18/2011
Commenter: RichardPurcell
Organization:Corp. Privacy Grp (CPG)
State:
Attachments: 00482-58114.pdf Size: 109 KB