Public Knowledge Files Comments Urging FTC To Create Comprehensive Rules for Data Privacy

Public Knowledge joined the Yale Law School Technology Accountability and Competition Project, a division of the Media Freedom and Information Access Clinic, in filing comments in the Federal Trade Commission’s proceeding on the prevalence of commercial surveillance and data security practices that harm consumers. Public Knowledge urges the agency to go beyond codifying the current failed notice and choice framework and build a data protection regime predicated on data minimization, data access rights for consumers, and protection of civil rights. Furthermore, Public Knowledge cautions the agency against over reliance on consent or anonymization techniques to solve for consumer harms that arise from data collection, use, and sale mechanisms. Public Knowledge also encourages the FTC to use its “truth in advertising” expertise as a foundation for building rules governing AI; in other words, the algorithm has to effectively and accurately do the thing the creators claim it can do.