In detailed comments, EPIC advised the FTC to strengthen a proposed settlement with ReadyTech concerning Privacy Shield, a framework that permits the flow of data on Europeans to the U.S. The FTC settlement prohibited the company from making future misrepresentations regarding compliance with Privacy Shield, but provided no relief for Europeans whose data was unlawfully collected. EPIC urged the FTC to require ReadyTech to undergo and release independent privacy assessments, disgorge all data collected from E.U. citizens, and implement Fair Information Practices. EPIC told the FTC that enforcement of Privacy Shield comes at a critical moment, as the European Parliament recently called for suspension by September 1st if the U.S. does not fully comply. EPIC stressed the urgency of the FTC’s Facebook-Cambridge Analytica investigation, which the European Parliament highlighted as a particular concern. EPIC previously told the FTC that the Cambridge Analytic breach could have been prevented had the FTC enforced the 2011 Consent Order against Facebook, which EPIC and other organizations helped obtain.
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