Submission Number: 00060
Received: 12/30/2011 5:10:29 PM
Commenter: Michael Schiffer
Agency: Federal Trade Commission
Initiative: Proposed Consent Agreement In the Matter of Facebook, Inc., FTC File No. 0923184
Attachments: No Attachments
This agreement fails to go far enough, particularly given Facebook's persistent "easier to get forgiveness than permission" history. At a bare minimum, users need to be able to maintain knowledge of and control over the information they provide to Facebook, including a right of deletion (with deletion to be confirmable, and any failure to comply subject to civil and criminal penalities, a right to know what information has been provided about them and to whom.
Most importantly, Facebook should be subject to random, unannounced audits by third parties, rather than having them be on a specific predetermined schedule. These audits should limited in number to not be unduly burdensome, but Facebook should not be in a position where it can arrange to only appear to be in compliance when a known deadline is approaching.