Commerce Department Seeking Public Input on Proposed Privacy Framework

By Cynthia J. Larose

 Yesterday, the Department of Commerce published a notice in the Federal Register, seeking feedback on proposals in its recently-unveiled privacy report.

    Among other questions, the Commerce Department is seeking comment on such issues as :

    • Should baseline commercial data privacy principles be enacted by statute or some other means?

    • How should baseline privacy principles be enforced?

    • As policymakers consider baseline privacy legislation, should they seek to grant the FTC the authority to issue more detailed rules?

    • Should baseline privacy legislation include a private right of action?

    • At what point in the development of a voluntary, enforceable code of conduct should the FTC review it for approval?

    • What steps or conditions are necessary to make a company's commitment to follow a code of conduct enforceable?

    In order to ensure that view of all stakeholders are taken into account in these important proceedings, we urge business to participate and file comments responding to the Commerce Department's (and the FTC) inquiry.   Comments are due by January 28, 2011.

 

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Cynthia J. Larose

Member / Chair, Privacy & Cybersecurity Practice

Cynthia J. Larose is Chair of the firm's Privacy & Cybersecurity Practice, a Certified Information Privacy Professional-US (CIPP-US), and a Certified Information Privacy Professional-Europe (CIPP-E). She works with clients in various industries to develop comprehensive information security programs on the front end, and provides timely counsel when it becomes necessary to respond to a data breach.