Comments

  • EPIC Comments to CBP on Biometric Identity

    October 29, 2024

    EPIC submits these comments opposing CBP's revision and extension of this information collection, particularly the use of facial recognition technology.

    • Face Surveillance & Biometrics

    • Surveillance Oversight

    • Traveler Screening & Border Surveillance

    • APA Comments

  • EPIC Letter to FCC Enforcement Bureau and Privacy and Data Protection Task Force (Oct. 2024)

    October 22, 2024

    • Communications Privacy

    • Consumer Privacy

    • Cybersecurity

    • Data Brokers

    • Data Protection

    • Data Security

    • Health and Reproductive Privacy

    • Location Tracking

    • Robocalls

    • APA Comments

  • Letter Comment Supporting Petition for Rulemaking to Amend Identity Theft Definitions in the Fair Credit Reporting Act (Regulation V)

    October 9, 2024

    • Consumer Privacy

    • Data Brokers

    • Comments

  • Comments of EPIC to the NY Attorney General on the NY SAFE for Kids Act

    October 1, 2024

    • Age Assurance

    • Children's Privacy

    • Consumer Privacy

    • Data Brokers

    • Data Protection

    • Platform Accountability & Governance

    • Platform Governance Laws & Regulations

    • The First Amendment

    • Comments

  • Feedback of EPIC to the European Commission regarding the First Periodic Review of the EU-US Data Privacy Frameworks

    September 5, 2024

    • Comments

  • Comments of the Electronic Privacy Information Center to the California Privacy Protection Agency on Proposed Rulemaking Regarding Data Broker Registration Regulations

    August 20, 2024

    EPIC supports the Agency’s efforts to enhance its data broker registry and rein in the privacy harms caused by the industry. EPIC supports the proposed regulatory clarifications and definitions and urges the Agency to require that data brokers supply an individual point of contact to be published on the registry.

    • Consumer Privacy

    • Data Brokers

    • Data Protection

    • Enforcement of Privacy Laws

    • Comments

  • Comments of EPIC to PCLOB AI in Counterterrorism July 2024

    July 3, 2024

    The Electronic Privacy Information Center (“EPIC”) submits these comments in response to the 2024 Request for Public Comment on the Role of Artificial Intelligence in Counterterrorism released by the Privacy and Civil Liberties Oversight Board (“PCLOB”) on May 23, 2024.

    • Artificial Intelligence and Human Rights

    • Face Surveillance & Biometrics

    • Government AI Use

    • Government Databases

    • Intelligence Surveillance

    • Surveillance Oversight

    • APA Comments

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

    May 1, 2024

    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

    April 22, 2024

    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.

    April 10, 2024

    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

    • APA Comments