November 9, 2018
Today, USTelecom responded to the National Telecommunications and Information Administration’s (NTIA) request for input on a national consumer privacy framework that protects consumers, prosperity and innovation.
We’re happy to add our voice to the digital privacy efforts happening across the Administration, the FTC, and in Congress.
Consumers expect and demand strong internet privacy protections and should have confidence in their online experiences. USTelecom supports this fundamental principle.
Ultimately, a national framework for digital privacy is going to require Congressional intervention. Unless and until Congress formulates federal legislation on privacy, the EU and individual states are going to keep stepping in with well-meaning but counterproductive privacy rules that create consumer confusion.
In our comments we outlined a framework of privacy principles that should be applied uniformly across the internet ecosystem and interoperable with existing multinational privacy regimes.
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- National Privacy Framework: Establish consistent privacy protections that are technology neutral and apply uniformly to companies that collect, use, or share a consumer’s online personal data and preempts individual state laws.
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- Transparency: USTelecom supports a requirement that companies give users clear and comprehensible information about the categories of data being collected, how consumer data is used, and the types of third parties with whom data may be shared.
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- Respect for Consumer Choice: USTelecom agrees that companies should give consumers easy to understand privacy choices based on the sensitivity of the data, how the data is being used or shared, and the purpose of that use. Companies should obtain consent when collecting sensitive personal information about children, health, finances and Social Security numbers.
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- Protect Personal Information: USTelecom supports requiring that companies take reasonable steps to protect consumer data and the continued use of anonymization techniques to minimize the risk associated with the collection, use, storage and sharing of a consumer’s personal data. Notification of breaches of consumer data stored or maintained by companies should be triggered by a determination that a breach has occurred that poses a reasonable risk of consumer financial harm.
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- Data Innovation: USTelecom supports affirmatively allowing innovative uses of data, while also encouraging the development of privacy-enhancing technologies and effective administrative safeguards.
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- Collaborative Public-Private Partnerships: USTelecom encourages voluntary privacy programs and standards be developed through public-private collaboration that could serve as a safe harbor in legislation while enabling companies to adapt to rapidly changing technology and market developments.
Finally, we suggested that the FTC remain the cop on the beat and be given additional resources and flexibility to bring enforcement actions when privacy and data security violations occur.
There’s no doubt we need a comprehensive, unified privacy blueprint that puts consumers first, builds trust and applies to all companies interacting with individuals on the internet.
As USTelecom’s Jonathan Spalter recently wrote: “USTelecom is committed to doing our part to shore up digital trust and give Americans the confidence that no matter what platform, device or network they choose, guardrails will be in place to protect their digital privacy and support our growing and interdependent internet ecosystem.”
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- Read USTelecom’s privacy comments to NTIA (November 9, 2018).
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- ICYMI, read Jonathan Spalter’s recent op-ed in Multichannel News on digital privacy: National Privacy Protections Need Now.