CCIA submitted comments to the Department of Commerce January 28th in response to the green paper they released in December entitled “Commercial Data Privacy and Innovation in the Internet Economy.” We applaud the Department of Commerce for undertaking the large task of addressing the complex and important issues surrounding consumer privacy and innovation on the Internet. The green paper raised thought provoking questions and insights that showed the long hours that must have gone into its production. We hope that our comments, along with all the rest of those received, will help the Department of Commerce as it moves forward with its work.
While the green paper raised many questions, CCIA’s reply addressed a few issues of particular importance to our members. We focused on three areas in particular: 1) achieving regulations for government surveillance that are clear, reasonable, and represent meaningful limits; 2) turning to Fair Information Practice Principles (FIPPs) as a baseline for protection of consumer privacy on the Internet, while maintaining that legislation in this area is still premature, and; 3) encouraging the convening of a collaborative process at the Department of Commerce to develop flexible and enforceable codes of conduct tailored to the privacy challenges of individual industries. We believe these suggestions can provide a way forward for privacy policy in the U.S. that will serve to encourage innovation, build trust in online companies, and provide users with the necessary transparency and control to participate in a conversation about privacy.
CCIA’s comments can be found on our website, and the Department of Commerce has a page listing all of the comments received during the period. We look forward to seeing how privacy policy at Commerce develops and to participate in the future in any way we can.