The Proliferation of Online Information Brokers and Reports of Abuses of Consumer Privacy


The Privacy Rights Clearinghouse (PRC) appreciates the opportunity to submit the following comments on the online information broker industry to the Federal Trade Commission (FTC) as part of the agency’s deliberations for the Privacy Roundtables series.

The online information broker industry has come to the forefront of consumer privacy issues in recent years. Information brokers are companies that compile information on individuals via public, semi-public and private records and offer this information via online “lookup” services, often with no questions asked. Some charge a fee while others provide their services at no charge. Consumers who are attempting to limit the availability of their personal information, due to concerns about privacy, safety or identity theft, have lodged numerous complaints against this industry with the PRC over the years.

Comments to Department of Health and Human Services re Breach Notification for Unsecured Protected Health Information


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

“Pay As You Drive” Automobile Insurance: The Need to Guard Personal Privacy


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.

Comments to the Los Angeles City Council: Public Policy Ramifications of Cloud Computing


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.

“Pay As You Drive” Automobile Insurance: Comments on the Need to Guard Personal Privacy


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.

Errors in Employment Background Checks: Harmful Long-Term Consequences for Individuals


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.

The Proliferation of Online Information Brokers: Noncompliance with Their Own Privacy Policies and Other Problems


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.

“Pay As You Drive” Automobile Insurance: Recommendations for Guarding Personal Privacy


Along with the potential good to come from reduced driving through PAYD insurance, there is a real risk that insurers will base attractive premiums on consumers’ willingness to accept onboard devices that record much more than miles traveled. Depending on the technology used, devices installed on personal automobiles may track speed, location, duration of a trip, acceleration and deceleration, time of day the trip was made, the identity of the driver, use of mobile phones and more. Once installed, a device originally set to track one driving element may be altered to add additional functions.

Uses of Social Security Numbers in the Private Sector: Why SSNs Are Not Appropriate for Authentication


The SSN has evolved since its establishment in 1935 and implementation in 1936 to be used as both an identifier and an authenticator. 

This morning, we heard from a panel of experts on the use of the Social Security number as an identifier.  As an identifier, the SSN is provided by individuals to answer the question, “Who are you?” As an authenticator, the topic of this panel, the SSN is provided by individuals in response to a challenge: “Prove who you are.”

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