Comments of CDT to the Department of Commerce on Information Privacy
The Commerce Department should advocate a privacy plan that consumers can trust in if it wants innovation to flourish in the global digital economy. In these comments, we present recommendations in response to the eight distinct issue areas addressed in the Notice of Inquiry as well as present a ninth topic – the impact on economic growth and innovation of unclear and outdated rules for access to consumer data by the US government. Throughout the comments, we explain why fully protecting consumer privacy interests online requires a rigorous mix of self-regulation, enforcement of existing law, regulatory activity, and enactment of new legislation. The Commerce Department should consider making a comprehensive set of recommendations setting out how industry and government can protect consumer privacy online and integrate privacy into online transactions and interactions.