Comments

Comments of EPIC to the CFPB On the Small Business Advisory Review Panel for Consumer Reporting Rulemaking

The Electronic Privacy Information Center submits these comments in response to the Consumer Financial Protection Bureau’s Small Business Advisory Review Panel for Consumer Reporting Rulemaking Outline of Proposals and Alternatives Under Consideration.

• Consumer Privacy

• Data Brokers

• Comments

EPIC Comments to the UK ICO’s Office for the Consultation on the Draft Biometric Data Guidance

• Anonymity

• Data Protection

• Democracy & Free Speech

• Face Surveillance & Biometrics

• International Privacy

• Location Tracking

• Privacy in Public

• Surveillance Oversight

• Comments

EPIC Comments to the FTC on Proposed Rulemaking to Amend the Health Breach Notification Rule

The Electronic Privacy Information Center (EPIC) submits these comments in support of the proposed changes and to share additional recommendations and expertise with the Commission.

• Cybersecurity

• Data Protection

• Data Security

• Health Privacy

• Comments

Comments of EPIC on CFPB Request for Information Regarding Data Brokers and Other Business Practices Involving the Collection and Sale of Consumer Information

Data brokers can and should be regulated under the FCRA, CFPA, and similar laws, and EPIC urges the CFPB to adopt an expansive definition of data broker misconduct to capture the variety of harmful activity that data brokers undertake; shift the regulatory burden from individual consumers exercising their rights to data brokers and other entities profiting off harmful data collection and use; coordinate efforts with the FTC to prioritize data minimization and data security within its regulations; and clarify its interpretations of FCRA provisions and definitions using illustrative examples.

• Consumer Privacy

• Data Brokers

• Comments

Comments of EPIC on HHS Proposed Rulemaking to Modify HIPAA Privacy Rule to Support Reproductive Health Care Privacy

The Electronic Privacy Information Center (EPIC) submits these comments in response to the Department of Health and Human Services (HHS)’s April 17, 2023 request for comment on its notice of proposed rulemaking to modify disclosure standards for protected health information under the Health Insurance Portability and Accountability Act (HIPAA) Privacy Rule and the Health Information Technology for Economic and Clinical Health Act (HITECH Act).[1] The proposed modifications would limit uses and disclosures of Protected Health Information (PHI) where the information relates to lawfully obtained reproductive health care.[2] EPIC commends HHS for taking meaningful steps to protect the privacy of people’s reproductive health information, but we recommend that the agency further strengthen the rule to ensure that these protections are not easily sidestepped, to raise the baseline level of protection for all health data to the constitutional standard, and to specifically overrule state mandatory reporting laws that would otherwise undermine the proposed rule. 

• Data Protection

• Health Privacy

• Comments

EPIC Comments to White House OSTP on Automated Worker Surveillance

Comments from EPIC to the Office of Science and Technology Policy providing resources on automated worker surveillance

• AI Policy

• Artificial Intelligence and Human Rights

• Commercial AI Use

• Data Protection

• Screening & Scoring

• Workplace Privacy

• Comments

EPIC Reply Comments to FCC on Martha Wright-Reed Act Implementation

EPIC's reply comments on the FCC's Implementation of the Martha Wright-Reed Act urged the agency to broadly and aggressively regulate prison phone telecommunications providers.

• Surveillance Oversight

• Wiretapping

• Comments

Comments of EPIC in re the Federal Trade Commission’s Proposed Order & Settlement with BetterHelp, Inc.

EPIC commends the Commission for using its Section 5 authority to take enforcement actions against companies like BetterHelp that are engaged in unfair and deceptive practices involving health data, especially where insufficient protections for personal information are involved.

• Data Protection

• Health Privacy

• Comments

Comments of EPIC to the National Telecommunications and Information Administration on Privacy, Equity, and Civil Rights

The Electronic Privacy Information Center (EPIC) submits these comments in response to The National Telecommunications and Information Administration (NTIA) Privacy, Equity, and Civil Rights Request for Comment posted on January 20, 2023.

• Comments

Comments of EPIC to OSTP on Digital Assets Request for Information

EPIC's comments to the White House OSTP advocating for research into a token-based intermediated central bank digital currency, fully anonymous digital cash, and fully anonymous credentials.

• Consumer Privacy

• Data Brokers

• Data Protection

• Government Records & Privacy

• Comments