ongress knew that the 1999 Gramm-Leach Bliley Financial Services Modernization Act (GLBA) - a law long-sought by the financial industry to encourage the creation of integrated financial services firms -- would exacerbate already-identified financial privacy threats. So Congress incorporated Title V to protect financial privacy, which included the following five key provisions. The most important and most successful is the last: the fail-safe states' rights provision allowing states to enact stronger financial privacy laws.
The Privacy Rights Clearinghouse (PRC) appreciates this opportunity to comment on the Department of Health and Human Services’ (HHS or Department) interim final rules regarding breach notification to individuals in the event of unauthorized use and access of protected health information. The rules, issued in coordination with the Federal Trade Commission (FTC), are mandated by Section 13402 of the Health Information Technology for Clinical Health (HITECH) A
Privacy Rights Clearinghouse and PrivacyActivism agree that a pay-drive plan that offers financial incentives for those who drive infrequently or who may choose to carpool or take public transportation has enormous potential for reducing traffic and protecting the environment. However, we respectfully disagree with the Commissioner’s statements in his August 3, 2009, press release that the regulations protect the privacy of California drivers.
Also, regrettably, neither the Department’s press release nor the amended regulations explain how the privacy of California drivers is protected.
I am writing to express concern about the proposal for the City of LA to implement Google Apps for its e-mail and office systems.
I am concerned about the propriety of a government entity using services that are “in the cloud,” so to speak, as repositories for sensitive personal and organizational information.
I question if enough is yet known about the privacy, security and confidentiality of personal information in a cloud environment.
On June 18, 2008, PRC and Privacy Activism responded to a call for comments when DOI first considered adopting a pay-drive program.
Our June 2008 comments discuss the serious threats to privacy inherent in a pay-drive program that depends on data gathered by onboard technology. Our concerns extended not only to the kinds of data collected by installed devices but also to the potential and unforeseen secondary uses of collected data. With few exceptions, our concerns about the threats to privacy and potential secondary uses of data remain essentially unchanged from those expressed in June 2008.
It is clear to the PRC that the problems of flawed background checks is not new to the FTC. It is also our belief that this is a critical area of consumer protection that deserves the increased attention of the FTC. Our analysis of FTC data uncovered numerous instances of complaints against the same company for reporting inaccurate data, often concerning criminal activities; failure to follow FCRA requirements for limiting information reported; and difficulty in getting the misinformation corrected.
There are dozens of information brokers in the marketplace today that make information about individuals widely available, often with no questions asked, some of them at no charge and others for a fee.
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