Comments to the Department of Commerce on Privacy Green Paper

Daniel Castro January 28, 2011
January 28, 2011

The Commerce Department Internet Policy Task Force put together a detailed framework for online privacy. In comments filed with the Department, ITIF says the paper provides many useful recommendations but also falls short in a number of areas. Specifically, the Task Force should seek to acquire more data to better understand user behavior and tradeoffs as it relates to privacy, rather than simply accept the conclusions of privacy advocacy groups that offer insufficient and outdated evidence. ITIF also recommends that Commerce should make clear that any new policies, including any fair information practice principles (FIPPs), be created in cooperation with the private sector. In addition, ITIF recommends that there be a greater emphasis on fostering policies that enable user choice. Finally, ITIF suggests the Commerce Department’s efforts should focus more on eliminating barriers to information sharing and allow consumer protection agencies like the Federal Trade Commission (FTC) take the lead on recommending appropriate policies to ensure consumer privacy.