EPIC, the Australian Privacy Foundation, and Privacy International submitted comments calling for a greater NGO role in oversight of the International Privacy Convention. The Council of Europe Convention 108+ is the first and only binding international legal instrument for data protection. Updated in 2018, the Modernized Convention includes new articles on biometric data and algorithmic transparency, and enhanced compliance with convention terms. The coalition comments urge the Council of Europe to include NGOs in compliance review groups, increase transparency of the review process, and to evaluate national privacy remedies and derogations from the Convention. EPIC and consumer groups have also long urged the United States to ratify the international Privacy Convention.
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