Regulatory Comments

Comments of TechFreedom & ICLE, In the Matter of Big Data and Consumer Privacy in the Internet Economy, NTIA

Summary

“…A serious assessment of the need for new privacy legislation, and the right way to frame it, would not begin by assuming the premise that a particular framework is necessary.
Specifically, before recommending any new legislation, the NTIA should do – or ensure that someone does – what the Federal Trade Commission has steadfastly refused to do: carefully
assess what is and is not already covered by existing U.S. laws…”

“Existing laws might well be inadequate to deal with some of the specific the challenges raised by Big Data. But until they are more carefully examined, we will not know where the
gaps are. Even those who might insist that there would be no harm to redundancy should agree that we must learn from the lessons of past experience with these laws. Moreover, it
is essential to understand what existing law covers because either (a) it will co-exist with any future privacy law, in which case companies will have potentially conflicting…”