Comments on Multistakeholder Process

drew einhorn [drew.einhorn@gmail.com]

Thu 3/1/2012 10:21 AM

Europe has extensive experience with much stronger privacy rules and regulations that the US.  Look to see what has and has not worked well for them.  

Companies who do not want to respect our privacy, will say:  "This is unworkable, we cannot live with this."  Tell them to look at Europe, where it has worked well for a long time.

--
Drew Einhorn

"You can see a lot by just looking."
  --  Yogi Berra

danandpat [dzatpz@cox.net]

Thu 3/1/2012 10:11 AM

“Google’s new privacy announcement is frustrating and a little frightening. “Even if the company believes that tracking users across all platforms improves their services, consumers should still have the option to opt out .

Secondly I now understand they have been collecting some information all along without permission. If we do not put a stop to it now where wil it end?

Liz Coker [liz.coker@3pmobile.com]

Sat 3/3/2012 12:51 PM

Dear Sir or Madame - 

The biggest issue in data privacy is that privacy policies are an all or nothing proposition on the Web.  There is absolutely no choice for the user other than use the service or not use the Web.  There is no chance for negotiation or exception.   Also, privacy policies are typically subject to change without notice, and most people are unaware of the changes when they occur.  To some extent, this is "just the nature of the Web."  Unless you actually sign up for a service with an account, notification can only happens the next time you visit a site – and typically nothing is posted – so you'd have to keep visiting the privacy policy section to see what, if anything has changed.

So to that end, a couple of suggestions.

• Privacy Policy changes should be noted on the home page of all sites "Privacy – last updated on 2/20/12"  or something of that nature
• Some sort of icon or emblem (like a movie rating system) should be displayed that indicates data usage policies (Just for us, we share with service delivery partners, we share with marketing/ad partners, we sell your data).
  • It could also be accomplished based upon some sort of registration process tied to domain management so the symbol automatically shows up in the address bar as a favicon.  Updates could be part of the domain registration verification process, so they are revisited on an ongoing basis. A simple check mark that indicates the type of data usage policy the site adheres to
• Privacy controls should allow for selective and elective sharing of data (I'll share my location, but not my name and I'll share  email, location, name and phone number with this other site).  
• Privacy controls should be software based and live on the device.  Server-initiated privacy management always puts the Web service in control and not the user.  This may be appropriate for a business with a mobile workforce, but it is not appropriate for consumer Web services.
• Data should be consider "property" and not "speech", as has been hinted by the Supreme Court.  This is, in my opinion, foolish and dangerous and in direct conflict with the intent of U.S. Bill of Rights.  
• Transparency is the key to success.  Privacy policies are typically hidden the ability to view profiles and collected data are either not present or difficult to find on most sites.  Most users will share personal information if they get value, but typically that value is not clear.  Statements like, "we use your location data to provide directions and deliver local ads and promotional offers" is clear and I can make a good decision.  Statements like, "we use your data to deliver a better experience" is vague and can have multiple meanings.

And in the spirit of transparency, I need to disclose that my company makes software that puts that level of choice in the user's hands without disrupting commerce.  We do it because we believe in it.  We believe that the policies and regulations should benefit everyone in the ecosystem and not just the elite Web brands, OS and browser companies.  I am both a citizen and business owner and can see the arguments on both sides.  The combination of choice and transparency satisfies both constituencies, with what I believe to be an appropriated balance

Thank you for considering my comments.

Respectfully,

-----------------------------------------------

Elizabeth Coker 
5o9, Inc.
Boulder, CO  USA

Improving the Mobile Web Experience

Office:  303.938.1769
Email:  liz.coker@3pmobile.com

Web site:  www.3pmobile.com

akline@godaddy.com

Thu 3/22/2012 3:08 PM

Attached...

andrew j. kline

deputy general counsel | global policy

go daddy operating co., llc |
400 north capitol street, nw | suite 585
washington, dc 20001 

Smith, Susan (Privacy & Information Management - Americas) [ssmith@hp.com]

Fri 3/23/2012 1:06 PM

HP is very encourage by the multi-stakeholder process and appreciates the opportunity to provide input.  Our comments are outlined in the attached document.

We would be pleased to participate in this process and look forward to contributing to this effort. 

Regards,

Susan

Susan Smith - Americas Privacy Officer - Hewlett-Packard - ssmith@hp.com

Helen Osman [HOsman@usccb.org]

Fri 3/23/2012 5:05 PM

Please find attached.

Terra Friedrichs

Sun 3/25/2012 8:49 PM

To the National Telecommunications and Information Administration:

I am responding to your request for public comment under the "Multistakeholder Process to Develop Consumer Data Privacy Codes of Conduct" Federal Register Notice, as part of your process to develop legally enforceable codes of conduct, presented at the following link:

http://www.ntia.doc.gov/federal-register-notice/2012/multistakeholder-process-develop-consumer-data-privacy-codes-conduct

Please make the following changes to the law:

1. "Automatic Opt-In" should be ONLY to provide the specific service that the consumer is opting in for.  Every provider using private data for inter-organizational sharing purposes should offer (in their initial "I accept these terms" choice) a "basic service option" that provides the consumer with protections against this sharing.  Sharing should be an "extra service", on top of the basic service.  The "basic service option" for an "automatic opt-in" should NOT include ANY sharing with ANYONE for marketing or other business/organizational development purposes, including companies within the same conglomerate.  If the consumer wants their data to be shared, there should be a special place for the consumer to go to "Opt-in" to the sharing program.  The current "Opt-Out" strategy is a trap because it requires the consumer to hunt down special tools to "opt-out", and the time it takes to find the tools is far longer than it takes the organization's computers to send our private information to their long list of "third party affiliates". 

Thus is makes even the most savvy technology users vulnerable.  Further, the current rules allowing for sharing of information among companies within conglomerates allows the common industry practice of preventing users from being able to opt out of this sharing.  This sets up an additional trap. That's because if you fill out a mortgage application with all of your personal information, and you get a mortgage from one company, your personal information can be sold along with the company as a conglomerate sweeps up industries worth of private information.

Because it's so difficult to get out of services, such as mortgages, or even email services, these sales of our private data and the bait-and-switch of private terms must be stopped.

2. Make it illegal to share credit card transactions and location information for marketing and/or profiling/political purposes, unless the consumer specifically "Opts-In" in a special "value added" service on top of the "basic service", as described in my first comment above. 

Currently, organizations sell and otherwise share our private transaction data.  Please make this illegal.

3. Make it illegal to change the "original uses" of personal data when a company is sold.  A common trick to get our information is to start a company with some kind of social cause.  The company has strict privacy policies and so people share openly. THEN the owners sell the company, and the new owner changes the policies.  Please make this illegal.

4. Please require any changes in privacy policies for use of personal information to require 1 years notice.

5. Please mandate that our private information is OUR PROPERTY.  Not the property of the person or organization that gathered it.

6. Please develop a civil review panel to review what NSA is doing with our data.  Gathering it is one thing. But we need to have public oversight as to what the factors are being used for correlating and profiling the data, and what can be done with the data once it is correlated.  Civic organizations such as the ACLU can be sworn in to top-secret status for the review purposes.  So those civilian representatives would not be able to share the specific factors being used, but can act as our consumer-rights advocates when the processes are being developed/reviewed.

Thank you for your attention to these grave concerns.  As you state in your request for comment, because of the use of advanced cloud and correlation/data warehousing techniques, the risk of abuse is increasing dramatically... as we speak.

Sincerely,

--

Terra

*~*~*~*

Terra Friedrichs

Systems Engineer

InfoSec Consultant

Privacy Activist

Joseph Santangelo [jsantangelo@axistechnologyllc.com]

Mon 3/26/2012 11:46 AM

With respect to usage of Consumer Data, there has been a great deal of time spent commenting on allowable uses of that are external to the company housing the data.  In terms of solidifying the security of this information, we want to address usage of Consumer Data within the company as well.    If we look at HIPAA as an example, Sections 164.514 (d)(2)(i)(A) and 164.306 indicate that covered entities (ie: companies housing consumer data) must ensure confidentiality and minimum necessary uses of protected health information (“PHI”) by those persons or classes of persons, as appropriate, in its workforce who need access to protected health information to carry out their duties.   A definition such as this would be beneficial.  Furthermore, it can be more specific to outline classes of employees who would not need access to Consumer Data (ie: offshore or onshore technology developers, third party business associates, etc.)

Regards,
Joseph Santangelo
Axis Technology, LLC

646-596-2670
jsantangelo@axistechnologyllc.com
www.axistechnologyllc.com
 @DataPrivacyDude

 linkedin.com/pub/joseph-santangelo/1/b21/63a

Irakli Kashibadze [ikashibadze@economy.ge]

Mon 3/26/2012 12:16 PM

Dear Mr/Ms

This is Irakli Kashibadze, Head of Communications, IT and Innovation Department of the Ministry of Economy and Sustainable Development of Georgia.  Please, below find the comment that I would like to be considered:

As the services provided by internet and mobile devices are becoming more and more irreplaceable, their usage is increasing daily. However, there arises Consumer Data Privacy issue that threatens safety of the whole world population.  I would like to identify some key points that in my opinion would improve current situation and be considerable for the multi stakeholder process.

1.       Practice has shown that consumers tempt not to read the Terms of Use, or Privacy Policy, before accepting specific conditions and entering their private date. This is caused mainly because the main priority of the consumer is to obtain the product itself and those conditions are put on the second place. I think this is most commonly experienced by children and teenagers. For this cause, I believe its vitally important to come up with the mechanism, wide awareness campaign that will inform and educate consumers of not only mobile apps but internet networks in general.
2.        Privacy should not hinder development of the services that make internet more smarter and consumer-oriented. However, in this case it is important to rise TRUST towards the companies that use this information. While working on the final document, this aspect should be considered.
3.       While coming up with the guidance for the mobile app developers, should be considered the factor of “Simpleness”. As too much bureaucracy might become an obstacle and demotivation for developers.

I have great hopes that the mutli stakeholter process will end up with the significant consensus that will preserve consumer privacy rights and will be beneficial for whole world population. 

Best Regards,

Irakli Kashibadze

Head of Communications, IT and Innovation Department

Ministry of Economy and Sustainable Development of Georgia

Tel: +(995 32) 2991115

Mob: +(995 595) 919911

E-mail: ikashibadze@economy.ge

URL: http://www.economy.ge

Melanie Wyne [MWyne@realtors.org]

Mon 3/26/2012 2:08 PM

Attached please find the comments of the National Association of Realtors to the Multistakeholder Process to Develop Consumer Privacy Data Codes of Conduct. Docket No. 120214135-2135-01.

Please let me know if I can answer any additional questions.

Sincerely,

Melanie Wyne

Melanie Wyne

Sr. Technology Policy Representative

National Association of Realtors

Twitter: @nartech

Zapanta, Juvy (US - McLean) [jzapanta@deloitte.com]

Mon 3/26/2012 3:59 PM

To Whom It May Concern

Deloitte  is pleased to submit our response to the Notice of Inquiry to serve NTIA. We are excited by the opportunity to provide comment and input to this initiative. We have a long-standing working relationship with the Department of Commerce and its programs.

We hope our response conveys our enthusiastic commitment to provide distinctive client service and highly specialized talent to NTIA, as you undertake a project with so much importance to our Nation. If you have any questions or require additional information, please contact Carey Miller at 571-882-6975 and/or email at caremiller@deloitte.com. Should you have any contractual questions, please contact me 703-885-6334 and/or email at jzapanta@deloitte.com.

P.S.  Please confirm receipt of this email at your earliest convenience.  Thank you. 

Juvy M. Zapanta

Contracts Manager|Federal Contracts & Procurement Group

Deloitte Services LP

1750 Tysons Blvd. Suite 800 Mclean,VA 22102

jzapanta@deloitte.com| www.deloitte.com

Please consider the environment before printing

Sarah A. Downey [sarah@getabine.com]

Mon 3/26/2012 5:02 PM

Dear Aaron:
Please find our comments attached, and let me know if you have any questions!

Regards,
-Sarah
--
Sarah A. Downey
Privacy Analyst  |  Attorney
Abine, The Online Privacy Company
t:  @SarahADowney

vernon irvin [virvin@vworldc.com]

Tue 3/27/2012 1:23 PM

Dear Assistant Secretary Strickling:

Thank you for accepting these comments regarding the Consumer Privacy Bill of Rights.

As you convene various stakeholders to develop consumer data privacy codes of conduct, I strongly encourage you to include companies and other organizations that can address the appropriate roles of private market solutions in issues like potential legislation, regulatory policy and industry self-regulation. 

We would encourage a process that includes discussion of strategies that encourage private market solutions that can respond to new technologies that circumvent privacy and security policies. Frankly, we believe the private sector can work within a set of basic guidelines and react to advances in technology much faster than government agencies can react and hope that idea is given weight during your challenging deliberations.

Vernon Irvin

CEO and President

Virtual World Computing,llc.

Rubinstein, Ira [Rubinstein@exchange.law.nyu.edu]

Tue 3/27/2012 3:35 PM

Please find attached our comments on the multistakeholder process. We would be happy to be of any further assistance.

Best

Ira Rubinstein and Dennis Hirsch

Sableman, Mark [MSABLEMAN@thompsoncoburn.com]

Fri 3/30/2012 11:42 AM

Mark Sableman

msableman@thompsoncoburn.com

Thompson Coburn LLP

One US Bank Plaza

St. Louis, MO  63101

www.thompsoncoburn.com

Manishin, Glenn B. [GBManishin@duanemorris.com]
Fri 3/30/2012 4:56 PM

Dear FTC Staff,

Attached for inclusion in the record of the captioned proceeding, Multistakeholder Process To Develop Consumer Data Privacy Codes of Conduct, is the response of Zix Corporation to NTIA’s request for public comments (77 Fed. Reg, 13908).

Please contact me with any questions or concerns. Thank you in advance for  your attention and cooperation.

Sincerely,

Glenn Manishin

=+=+=+=+=+=+=+=+=+=+=+=+=+=
Glenn B. Manishin, Esq.
Duane Morris LLP
505 9th Street, N.W., Suite 1000
Washington, DC 20004
202.776.7813
202.478.2875 fax
202.256.4600 cell
<gbmanishin@duanemorris.com>
=+=+=+=+=+=+=+=+=+=+=+=+=+=

Jeffrey Chester [jeff@democraticmedia.org]
Mon 4/2/2012 8:30 AM

Rahul Jain (DSCI) [rahul.jain@dsci.in]
Mon 4/2/2012 8:56 AM

Dear Sir / Madam

Data Security Council of India (DSCI) is pleased to submit its comments on NTIA multi-stakeholder process for development of data privacy codes of conduct. In case of any queries / clarifications on these comments, please let us know. Going forward, we will be pleased to work with NTIA and contribute in the development of the Consumer Data Privacy Codes of Conduct.

Request acknowledgement of this mail. Thank you.

Regards,

Rahul Jain | Senior Consultant - Security Practices | DATA SECURITY COUNCIL OF INDIA (DSCI) | A NASSCOM® Initiative

L: Niryat Bhawan, 3rd Floor | Rao Tula Ram Marg | New Delhi - 110057, India

P: +91-11-26155071 | F: +91-11-26155070 | www.dsci.in

@dsci_connect |  @dsci.connect |  dsci.in/rss.xml

@company/data-security-council-of-india

Ashley Creel [acreel@techpolicyinstitute.org]
Mon 4/2/2012 9:15 AM

Doug Thompson [Doug.Thompson@RILA.ORG]
Mon 4/2/2012 10:01 AM

Attached is a comment letter from the Retail Industry Leaders Association on the privacy multistakeholder process to develop consumer data privacy codes of conduct. We appreciate the opportunity to offer our thoughts and concerns.

Doug Thompson

Vice President, Government Affairs

Retail Industry Leaders Association (RILA)

1700 North Moore Street

Suite 2250

Arlington, VA 22209

(703) 600-2065 work

(703) 841-1184 fax

www.RILA.org

Follow RILA

Linkedin |@RILAtweets|Facebook

Halataei, Andrew [ahalataei@itic.org]
Mon 4/2/2012 10:58 AM

National Telecommunications and Information Administration

U.S. Department of Commerce

1401 Constitution Avenue, N.W.

Room 4725

Washington, D.C.  20230

RE:  Multistakeholder Process to Develop Consumer Data Privacy Codes of Conduct

The Information Technology Industry Council (ITI) represents fifty of the nation’s leading information and communications technology (ICT) companies, including computer hardware and software, Internet services, and wireline and wireless networking companies.  ITI is the voice of the high-tech community, advocating policies that advance U.S. leadership in technology and innovation, open access to new and emerging markets, support e-commerce expansion, and enhance domestic global competition.

ITI welcomes the opportunity to provide comments on this matter, which is of great importance to the ICT sector and appreciates the National Telecommunications and Information Administration’s thoughtful approach on this and many other issues related to the technology industry.  We wish to comment on the Multistakeholder Process to Develop Consumer Data Privacy Codes of Conduct and the specifics of the meeting processes.

We applaud your efforts to keep the discussions open and transparent.  The Multistakeholder Process has the potential to produce healthy, constructive discussions among participants.   However, the NTIA should proceed with great diligence and it is important to bear in mind that the industry does abide by already-established codes of conduct.  It is our belief that the three basic principles should be followed.

First, a general consensus should be a chief concern.  Multistakeholder meetings can become cumbersome with a single dissenting viewpoint diluting productivity.  While it is important for minority views to be considered, NTIA should also seek to limit the influence of a single critic; whether from industry, an advocacy organization, or any other stakeholder participating in the process.  Recognizing this potential problem will ensure the discussions do not become unrepresentative and unwieldy.  In addition to developing a consensus on process and procedure within the Multistakeholder Process, NTIA may also wish to consult stakeholders on the policy framework and principles upon which codes of conduct may be based such as those outlined in the White House Privacy Bill of Rights.

Second, NTIA should, whenever possible, seek to build on existing multistakeholder discussions that have already taken place.  For instance, a great deal of valuable work has already taken place around improving transparency and consumer disclosure in mobile applications.  Those very fruitful discussions can serve as a starting point for a new multistakeholder process under the Department of Commerce.

Finally, NTIA should consider multiple structures to conduct the meetings.  Discussions among all participants may at times be appropriate.  There may also be occasions when discussions should be conducted among smaller, like-minded working groups made up of the appropriate mix of stakeholders.  Adopting both formats for the deliberations will reduce the risk that relations among those with differing viewpoints become strained.  It will also ensure that companies are able to have a frank and transparent discussion without fear of divulging trade secrets or enforcement from regulators.

 We applaud the Administration’s willingness to address this issue.  Without question, privacy issues are of paramount importance to consumers and our companies.   Each of our members agrees that consumers should be able to protect their personal information online.  As such, the industry has already developed and implemented a wide-ranging, self-regulating apparatus that protects both the consumer while preserving the ability of industry to innovate and bring new products to market.  We agree that consumer confidence is key to industry growth and innovation.

ITI appreciates NTIA’s commitment to industry outreach and engagement with stakeholders to produce effective policy.  In particular, we appreciate the opportunity to comment on the Mutistakeholder Process to Develop Consumer Data Privacy Codes of Conduct, and we hope that our comments are useful and will receive due consideration as you move forward.  We remain available at any time to elaborate on our comments and suggestions.

Sincerely,

Andy Halataei

Director of Government Relations

Information Technology Industry Council

202-626-5722

703-785-6972 (cell)

1101 K Street, NW

Suite 610

Washington, DC 20005

ahalataei@itic.org

Website: www.itic.org

Twitter: @TechElect

Allie Hagan [ahagan@pennhillgroup.com]
Mon 4/2/2012 11:46 AM

To whom it may concern, 

These comments are respectfully submitted on behalf of Jason Schultz and other listed signatories.

-Allie.

Allie Hagan
Penn Hill Group
777 6th Street NW

Suite 650
Washington DC 20001
(202) 618-3900 (Main)

(202) 510-9997 (Direct)

(202) 503-5220 (Cell)

www.pennhillgroup.com

Amos, Renee [ramos@ahip.org]; on behalf of; Zigmund Luke, Marilyn [MZLuke@ahip.org]
Mon 4/2/2012 12:09 PM

Renee Amos

Executive Assistant, Legal Department

AHIP

601 Pennsylvania Avenue, NW, Ste 500

Washington, DC  20004

(202) 778-3211 (ph)

(202) 778-8466 (fax)

ramos@ahip.org

www.ahip.org

Providing Health Benefits for Over 200 Million Americans

Mark MacCarthy [mmaccarthy@SIIA.net]
Mon 4/2/2012 12:18 PM

All,

Attached please find SIIA’s comments in this proceeding.

Best,

Mark

Mark MacCarthy

Vice President, Public Policy

Software & Information Industry Association

1090 Vermont Ave. NW Sixth Floor

Washington, DC 20005

202-579-7337

Attached please find the comments of the Future of Privacy Forum in response to NTIA’s March 5 request for comments regarding the multistakeholder process to develop consumer data privacy codes of conduct.

Please let me know if you have any questions.

Regards,

Mark

Mark Brennan
Attorney at Law

Please consider the environment before printing this e-mail.

Jones, Anthony V. [ajones@ustelecom.org]
Mon 4/2/2012 1:08 PM

NTIA privacyrfc2012@ntia.doc.gov:

Attached are USTelecom Comments submitted re NTIA Docket No. 120214135-2135-01, Multistakeholder Process To Develop Consumer Data Privacy Codes of Conduct.

Anthony V. Jones

Senior Paralegal

United States Telecom Association

607- 14th Street, NW│Suite 400│Washington, DC 20005-2051 202.326.7277│www.ustelecom.org

John Simpson [john@consumerwatchdog.org]
Mon 4/2/2012 1:51 PM

Attached as a PDF file, please find Consumer Watchdog's comments on “Multi-stakeholder Process To Develop Consumer Data Privacy Codes of Conduct”, Docket No. 120214135–2135–01

Thank you.

John M. Simpson

Privacy Project Director

Consumer Watchdog

1750 Ocean Park Blvd. ,Suite 200

Santa Monica, CA,90405

www.consumerwatchdog.org

Huseman, Brian [brian.huseman@intel.com]
Mon 4/2/2012 2:04 PM

Intel Corporation submits the attached comments on the Multistakeholder Process to Develop Consumer Data Privacy Codes of Conduct.

Thank you.

Brian Huseman

Intel Corporation

Pam Dixon [pdixon@worldprivacyforum.org]
Mon 4/2/2012 2:30 PM

Attached please find the comments of the World Privacy Forum et al regarding the MultiStakeholder process to develop codes of conduct, Federal Register, March 2, 2012 at 77 Federal Register 13098. (http://www.ntia.doc.gov/files/ntia/publications/fr_privacy_rfc_notice_03052012_0.pdf. )We have attached the document in text form in this email as well as in PDF and Word form. If there are any questions or difficulties opening the files, please contact Pam Dixon at 760-712-4281.

Respectfully submitted, 

Pam Dixon 

World Privacy Forum 

pdixon@worldprivacyforum.org

Koslofsky, Jason [Koslofsky.Jason@ARENTFOX.COM]
Mon 4/2/2012 2:33 PM

The attached comments are submitted on behalf of the Application Developers Alliance in Docket No. 120214135-2135-01. 

Please confirm receipt.

Thank you,

Jason Koslofsky

Jason Koslofsky

Attorney

Arent Fox LLP | Attorneys at Law

1050 Connecticut Avenue, NW

Washington, DC  20036-5339

202.857.8969 DIRECT | 202.857.6395 FAX

koslofsky.jason@arentfox.com | www.arentfox.com

Kelsey Nussenfeld [knussenfeld@holcherickson.com]
Mon 4/2/2012 3:04 PM

Good afternoon,

Please see the attached comments of NetCoalition in response to the NTIA’s Request for Comment on a proposed multistakeholder process to develop data privacy best practices. The comments on behalf of NetCoalition are submitted by Markham Erickson, Executive Director and General Counsel for the coalition. A word and pdf version are included for convenience.

Sincerely,

Kelsey

Kelsey Nussenfeld

Holch & Erickson

400 N. Capitol St. NW Suite 585 | Washington, DC 20001
Phone: (202) 624-1464   

Fax: (202) 393-5218
knussenfeld@holcherickson.com

kevin@spatiallaw.com
Mon 4/2/2012 3:05 PM

Please find attached comments from the Centre for Spatial Law and Policy on the Multistakholder Process To Develop Consumer Data Privacy Codes of Conduct. Feel free to contact me if you have any questions or comments. KDP

Kevin Pomfret

Executive Director

804.928.5870

Centre for Spatial Law and Policy

kevin@spatiallaw.com

Twitter

Howard Fienberg [Howard.Fienberg@MarketingResearch.org]
Mon 4/2/2012 3:31 PM

Dear Mr. Burstein,

I hereby submit the attached comments on behalf of the Marketing Research Association (MRA) in response to the NTIA’s March 5, 2012 Request for Public Comments, “Multistakeholder Process To Develop Consumer Data Privacy Codes of Conduct.”

Sincerely,
 
Howard Fienberg, PLC
Director of Government Affairs
Marketing Research Association (MRA)

Brandt, Allen [abrandt@gmac.com]
Mon 4/2/2012 3:32 PM

Aaron: I have attached GMAC’s comments to the Multistakeholder Process To Develop Consumer Data Privacy Codes of Conduct.

Please contact me if you have any questions.

Thanks,

Allen

Allen Brandt
Corporate Counsel, Chief Privacy Official
Director, GMAC MET Fund

Graduate Management Admission Council®, (GMAC®), Graduate Management Admission Test® and GMAT® are registered trademarks of the Graduate Management Admission Council® (GMAC®). All rights reserved.

Michelle De Mooy [michelle.demooy@consumer-action.org]
Mon 4/2/2012 3:35 PM

Below please find the full text of Consumer Action's comments to the NTIA on the Multistakeholder Process to Develop Consumer Data Privacy Codes of Conduct. I've also attached the comments to this email as a .pdf document. 

Thank you for the opportunity to comment,

Michelle De Mooy

Ioana Rusu [irusu@consumer.org]
Mon 4/2/2012 3:39 PM

To Whom It May Concern:

Please find attached our letter in response to the NTIA request for public comments, entitled, Multistakeholder Process to Develop Consumer Data Privacy Codes of Conduct. I am submitting this letter on behalf of Consumers Union, Consumer Federation of America, Privacy Times, and The Benton Foundation.

Please do not hesitate to contact me with any questions or concerns.

Regards,

Ioana Rusu

--

  Ioana Rusu
  Regulatory Counsel
  Consumers Union - Washington Office
  1101 17th Street, NW Suite 500
  Washington, DC 20036
  Tel: (202) 462-6262
  irusu@consumer.org

Signorelli, Michael A. [MASignorelli@Venable.com]
Mon 4/2/2012 3:44 PM

Attached are the comments of the Interactive Advertising Bureau in response to the National Telecommunication and Information Administration’s request for input on multistakeholder processes to develop consumer data privacy codes of conduct.  Thank you

Michael A. Signorelli, Esq. | Venable LLP
t 202.344.8050 | f 202.344.8300
575 7th Street, NW, Washington , DC 20004

MASignorelli@Venable.com | www.Venable.com

Berin Szoka [bszoka@techfreedom.org]
Mon 4/2/2012 3:50 PM

Please find my comments attached.  Thanks!

--
Berin Szoka | President, TechFreedom

bszoka@techfreedom.org | @BerinSzoka

Gretchen Lohmann [GLohmann@NCTA.com]
Mon 4/2/2012 3:56 PM

Good afternoon:

Attached are the comments of the National Cable & Telecommunications Association in Docket No. 120214135-2203-02 regarding the Multistakeholder Process proceeding.

Gretchen M. Lohmann

Legal Assistant

National Cable & Telecommunications Association

25 Massachusetts Ave., N.W., Suite 100

Washington, D.C.  20001-1431

Ph: 202-222-2445; 202-222-2452 (Direct)

Fax: 202-222-2446

Tama, Julia Kernochan [JATama@Venable.com]
Mon 4/2/2012 4:00 PM

Attached are the comments of the Direct Marketing Association in response to the National Telecommunication and Information Administration’s request for input on multistakeholder processes to develop consumer data privacy codes of conduct.  Thank you.

Julia Kernochan Tama, Esq. | Venable LLP
t 202.344.4738 | f 202.344.8300
575 7th Street, NW, Washington, DC 20004

JKTama@Venable.com | www.Venable.com

Claudia Tamayo [CTamayo@ctia.org]
Mon 4/2/2012 4:01 PM

Please find attached CTIA’s comments regarding Multistakeholder Process to Develop Consumer Data Privacy Codes of Conduct, Docket No. 120214135-2135-01.

Should you have any questions, please contact Michael Altschul at 202-736-3248/maltschul@ctia.org or Athena Polydorou at 202-736-3259/apolydorou@ctia.org.

Thank you, 

Claudia Tamayo

Executive Coordinator | General Counsel

CTIA-The Wireless Association®

1400 16th Street, NW, Suite 600
Washington, DC 20036
direct:   202-736-3249  |  fax: 202-785-8203 

e-mail: ctamayo@ctia.org

David Bruggeman [bruggeman_d@hq.acm.org]
Mon 4/2/2012 4:08 PM

Hello,

Attached please find the comments of the U.S. Public Policy Council of the Association for Computing Machinery (USACM) in response to the NTIA request for comment dated March 5, 2012 and titled Multistakeholder Process To Develop Consumer Data Privacy Codes of Conduct.  If you have any questions or need additional information, please contact our Director of Public Policy, Cameron Wilson, at 212-626-0541.

Regards,

David Bruggeman

Senior Public Policy Analyst

Association for Computing Machinery

1828 L Street, Suite 800

Washington, D.C. 20036

212-626-0542

212-626-0541 (main line)

david.bruggeman@acm.org

http://www.usacm.acm.org

Boyd, Tom [Tom.Boyd@dlapiper.com]
Mon 4/2/2012 4:11 PM

Attached are the comments of the National Business Coalition to the NTIA's March 5, 2012, request for comment on the Department of Commerce's Multi-stakeholder Process. Please confirm receipt.

Thomas M. Boyd

DLA Piper US LLP

500 8th Street, NW

Washington, D.C.  20004

T 202.799.4361

F 202.799.5361

tom.boyd@dlapiper.com

Mark Uncapher [MUncapher@tiaonline.org]
Mon 4/2/2012 4:13 PM

Attached for your consideration.

Mark Uncapher

Mark Uncapher
Director, Regulatory & Government Affairs

Telecommunications Industry Association (TIA)

d: 202.346.3244 | m: 202.423.5344

10 G Street, N.E., Suite 550

Washington, DC 20002 
MUncapher@tiaonline.org | tiaonline.org

Ross Schulman [rschulman@ccianet.org]
Mon 4/2/2012 4:16 PM

Please see the attached pdf file containing the comments of the Computer and Communications Industry Association in response to the February 29, 2012 RFC.

Thank you,
Ross Schulman

--
Ross Schulman

Public Policy & Regulatory Counsel 
Computer & Communications Industry Association 
(202) 470-3616 | rschulman@ccianet.org

Beth Givens [bethg@privacyrights.org]
Mon 4/2/2012 4:21 PM

To NTIA:

Attached are the comments of the Privacy Rights Clearinghouse concerning the NTIA's Multistakeholder Process to Develop Consumer Data Privacy Codes of Conduct, Docket No. 120114135-2135-01.

Thank you for your consideration of our Comments.

Sincerely,

Beth Givens
Director

The information, advice, and suggestions contained in this email
should be used as an information source and not as legal advice.

Beth Givens, Director
Privacy Rights Clearinghouse
3108 - 5th Ave., Suite A
San Diego, CA 92103
Voice:  619-298-3396
Fax:  619-298-5681
bethg@privacyrights.org
http://www.privacyrights.org

Guilherme Roschke [GRoschke@commonsense.org]
Mon 4/2/2012 4:24 PM

Attached please find our Comments on the Stakeholder Process.

-gr

----

Guilherme Roschke

Policy Counsel | Common Sense Media 
Phone: 202.999.8281

groschke@commonsense.org | www.commonsensemedia.org

Chris Wilson [chris.wilson@techamerica.org]
Mon 4/2/2012 4:27 PM

Please find attached TechAmerica’s comments re the multistakeholder process.  Thank you.

Christopher E. Wilson

Vice President and Counsel,

Communications, Privacy, and Internet Policy

TechAmerica

601 Pennsylvania Ave., NW

Suite 600, North Building

Washington, D.C. 20004

Phone: (202) 682-4451

Ioana Rusu [irusu@consumer.org]
Mon 4/2/2012 4:27 PM

To Whom It May Concern:

Please find attached the results of a Consumer Reports survey, which sought to determine which privacy issues consumers are most concerned about. In addition, we reached out to our grassroots activists and asked them to tell us which substantive issues the NTIA multistakeholder process should take on first. Those responses are also attached.

Please do not hesitate to contact me with any questions or concerns.

Best,

Ioana Rusu

--

  Ioana Rusu
  Regulatory Counsel
  Consumers Union - Washington Office
  1101 17th Street, NW Suite 500
  Washington, DC 20036
  Tel: (202) 462-6262
  irusu@consumer.org

John Stephenson [jstephenson@alec.org]
Mon 4/2/2012 4:31 PM

To Whom It May Concern:

For your consideration, the chairmen of the American Legislative Exchange Council’s Communications and Technology Task Force submit the attached comment as part of the Multistakeholder Process To Develop Consumer Data Privacy Codes of Conduct.

Thank you,

John Stephenson

Director, Communications and Technology Task Force

American Legislative Exchange Council

1101 Vermont Avenue, NW

11^th Floor

Washington, DC 20005

Office: 202-742-8524

Fax: 202-466-3801