Comments

Workado, LLC., FTC File No. 232-3092

June 3, 2025

• Artificial Intelligence and Human Rights

• Consumer Privacy

• Data Protection

• Comments

Coalition Comment to the CPPA on Rulemaking on Risk Assessments, Cybersecurity, and ADMTs

June 3, 2025

The revised draft regulations released on May 9, 2025 represent significant concessions by the Agency and its board to a campaign of industry pressure.

• AI Policy

• Artificial Intelligence and Human Rights

• Privacy Laws

• Risk Assessments

• U.S. State Privacy Laws

• Comments

Coalition Comment to the CPPA on Rulemaking on Risk Assessment, Cybersecurity, and ADMT

June 3, 2025

The undersigned organizations are deeply disappointed at the substantial weakening of the CPPA's proposed regulations.

• AI Policy

• Artificial Intelligence and Human Rights

• Privacy Laws

• Risk Assessments

• U.S. State Privacy Laws

• Comments

Comments of EPIC to Congresswoman Lori Trahan on Efforts to Reform Privacy Act of 1974 and Protect Americans’ Data from Government Abuse

May 7, 2025

The Electronic Privacy Information Center (EPIC) submits these comments in response to Congresswoman Lori Trahan’s March 18, 2025, request for information on modernizing the Privacy Act of 1974. EPIC strongly supports amending the Act to limit its disclosure exceptions, to establish standards for personnel that handle systems of records, and to address the risks posed by emerging technologies. EPIC further stresses that Congress must ensure that agencies are adequately funded and staffed to implement privacy protections for decades to come.

• Data Protection

• Defeating the DOGE

• Government Databases

• Government Records & Privacy

• Privacy Laws

• Surveillance Oversight

• U.S. Privacy Laws

• Comments

Comments of EPIC, NCL, and CFA on the Protecting Americans from Harmful Data Broker Practices Notice of Proposed Rulemaking

April 2, 2025

• Consumer Privacy

• Cybersecurity

• Data Brokers

• Data Security

• Privacy Laws

• U.S. Privacy Laws

• Comments

Comments to the CPPA on Proposed Regulations Regarding Cybersecurity, Risk Assessments, and ADMTs

February 20, 2025

We commend the Agency for taking steps to protect consumers from the significant privacy harms caused by the use of automated decisionmaking technologies and the processing of personal data without adequate assessment and mitigation of the resulting privacy and security risks.

• AI Policy

• Artificial Intelligence and Human Rights

• Consumer Privacy

• Data Minimization

• Risk Assessments

• Comments

Comments of EPIC in re the Federal Trade Commission’s Proposed Order & Settlement with Mobilewalla

January 13, 2025

• Consumer Privacy

• Data Brokers

• Data Minimization

• Data Protection

• Location Tracking

• Online Advertising & Tracking

• Comments

EPIC Comments to Dutch DPA on Emotion Recognition Prohibition under EU AI Act

December 17, 2024

By notice published on October 31, 2024, the Netherlands’ Autoriteit Persoonsgegevens (“AP”) sought input1 on its interpretation of the sixth prohibition of Regulation (EU) 2024/1689 (hereinafter the “AI Act”)2 which prohibits AI systems intended to identify or infer the emotions or intentions of natural persons (“emotion recognition systems”)3 in the areas of workplace or education institutions based on biometric data (“Prohibition F”).4

• AI Policy

• Artificial Intelligence and Human Rights

• Data Protection

• International Privacy

• Student Privacy

• Workplace Privacy

• Comments

Joint Comment Regarding OMB’s Request for Information on Executive Branch Agency Handling of Commercially Available Information

December 17, 2024

This comment highlights one dangerous aspect of agency handling of CAI that demands OMB’s attention: law enforcement and intelligence agencies’ access to and use of CAI in ways that evade legal requirements set forth in the Fourth Amendment and various privacy laws enacted by Congress. We discuss the Fourth Amendment doctrines and statutes that restrict the government surveillance at issue here, how the government is using CAI to circumvent those rules, the harms of this circumvention, and recommendations that OMB should implement to regulate these practices.

• Consumer Privacy

• Data Brokers

• Intelligence Surveillance

• Surveillance Oversight

• 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