Submission Number: 00231
Received: 1/18/2011 3:07:46 AM
Commenter: Madolyn Orr
Agency: Federal Trade Commission
Initiative: A Preliminary FTC Staff Report on "Protecting Consumer Privacy in an Era of Rapid Change: A Proposed Framework for Businesses and Policymakers"
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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.