Comments

  • Comments of EPIC to the Office of the Privacy Commissioner of Canada Regarding the Update to Guidance on Handling Biometric Information

    By notices published October 11, 2023, the Office of the Privacy Commissioner of Canada (“OPC”) has solicited input on its guidance for both public1 and private2 sector organizations handling biometric information, to close on January 12, 2024.3 These guidance documents are intended to update the biometrics guidance first published in 2011 and address evolutions in biometric technology and use as well as addressing how both the Personal Information Protection and Electronic Documents Act (“PIPEDA”) and the Privacy Act intersect with biometric information processing. Pursuant to the request for input on the updated guidance documents, the Electronic Privacy Information Center (“EPIC”) submits the following comments. 

    • Data Protection

    • Face Surveillance & Biometrics

    • International Privacy

    • Surveillance Oversight

    • Comments

  • EPIC Comments to UK ICO Call for Views on “Consent or Pay” Business Models

    By notice published March 6, 2024, the United Kingdom’s Information Commissioner’s Office (“UK ICO” or “the ICO”) has called for views regarding “consent or pay” business models (hereinafter “the Consultation”) to close on April 17, 2024.[1] This Consultation is intended to address an emerging business model where individuals are blocked from accessing a website unless they consent to their personal information being processed for the purpose of targeted advertising, or, as the ICO puts it, “pay a fee and not be tracked.”

    • Consumer Privacy

    • Data Protection

    • International Privacy

    • International Privacy Laws

    • Privacy Laws

    • Web Scraping

    • Comments

  • Comments of EPIC in re the Federal Trade Commission’s Proposed Consent Order with Avast, Ltd. et al.

    EPIC commends the Commission for using its authority to investigate and take enforcement actions against companies like Avast engaged in unfair and deceptive practices, especially where companies wrongfully profit from the selling of web browsing data and other sensitive information. Avast exploited users’ desire for privacy protections by promising that its software would block tracking technologies that collect browsing information—while selling such data itself. We support the Commission’s enforcement action against Avast, and we offer two recommendations to make the final Order even stronger: (1) the Commission should extend the core prohibition of the Order to cover sales or disclosures of browsing data for other purposes, such as sales of data to government contractors for national security purposes; and (2) the Commission should incorporate a comprehensive data minimization framework with express collection, processing, transfer, and retention limits.

    • Consumer Privacy

    • Data Brokers

    • Data Protection

    • Intelligence Surveillance

    • Surveillance Oversight

    • Comments

  • Comments of EPIC to U.S. Commission on Civil Rights on Facial Recognition Technology

    • Face Surveillance & Biometrics

    • Surveillance Oversight

    • Comments

  • Comments of EPIC to the UK Department for Education on Gender Questioning Children

    By notice published December 19, 2023, the United Kingdom’s Department for Education (hereinafter “the Department”) has solicited feedback on its draft consultation regarding Gender Questioning Children (hereinafter “the Consultation”),[1] to close on March 12, 2024.[2] This Consultation is intended to address social transitioning in schools by minors who are questioning their gender identity. Pursuant to the request for views on how to best support schools to inform the Department’s work in this area, the Electronic Privacy Information Center (“EPIC”) submits the following comments.

    • Children's Privacy

    • Data Protection

    • International Privacy

    • Student Privacy

    • Comments

  • Comments of EPIC in re the Federal Trade Commission’s Proposed Consent Order with InMarket Media LLC

    EPIC commends the Commission for using its authority to investigate and take enforcement action against companies like InMarket that use misleadingly obtained data to create and maintain consumer profiles for targeted advertising.

    • Consumer Privacy

    • Data Protection

    • Location Tracking

    • Comments

  • Comments of EPIC, Demand Progress, and EFF in re the Federal Trade Commission’s Proposed Order & Settlement with X-Mode Social, Inc.

    EPIC, Demand Progress, and EFF submitted this letter to applaud the FTC’s enforcement efforts in this matter and to provide recommendations to strengthen the proposed order (and others like it in future cases concerning location data).

    • Data Protection

    • Location Tracking

    • Privacy in Public

    • Surveillance Oversight

    • Comments

  • EPIC Comments on Colorado Universal Opt-Out Mechanism (UOOM) Shortlist

    EPIC encourages the Department of Law to approve GPC before the Department’s January 1, 2024 deadline, to seek additional information from OOC for a potential later approval date, and to decline to approve TOOM unless it undergoes substantial revision.

    • Communications Privacy

    • Consumer Privacy

    • Data Brokers

    • Data Protection

    • Location Tracking

    • Social Media Privacy

    • Comments

  • Office of Management and Budget Memorandum on Use of AI in Government

    • AI in the Criminal Justice System

    • AI Policy

    • Artificial Intelligence and Human Rights

    • Commercial AI Use

    • Government AI Use

    • Open Government

    • 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