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.”

Social Security Numbers in the Private Sector: Comments to the FTC


Consumers often are coerced into providing an SSN as a means of authentication or verification, where appropriate authentication could be achieved through other means.  Our PRC consumer hotline receives numerous calls from concerned individuals who are reluctant to provide this information either by telephone or online.  They have heard the warnings about guarding their SSNs to protect themselves from identity theft.  Yet paradoxically, they are afraid to take advantage of two important services that can help reduce their potential exposure to identity theft.

Interagency Proposal for Model Privacy Form under the Gramm-Leach Bliley Act


The Privacy Rights Clearinghouse (PRC)1 is pleased to comment on the Federal Trade Commission (FTC or Commission) notice of proposed rulemaking (NPR)2 to simplify the consumer disclosures required by the Gramm-Leach-Bliley Act (“GLB”). With only a few minor suggestions, the PRC endorses and fully supports the model form adopted by the agencies. We direct our comments as follows:

Prerecorded Telemarketing Calls: The Need for Industry Reform


VMBC petitioned the Commission to amend the TSR to allow prerecorded telemarketing calls to consumers when the caller has a claimed business relation. If accepted, an EBR exception for prerecorded sales calls would have created a major loophole, opening the door for a dramatic increase in unwanted calls to consumers who had placed their telephone numbers on the national Do-Not-Call (DNC) Registry.

Identity Theft Red Flags and Address Discrepancies under the Fair and Accurate Credit Transactions Act of 2003


The detection of red flags and the need to reconcile address discrepancies are among the most important anti-identity theft measures included in FACTA. Effective business policies and practices that spot attempted and actual identity theft early have great potential for relieving this national crime wave. This was the promise and Congress’ intent when it directed the Agencies to adopt Red Flag Regulations along with procedures to reconcile address discrepancies in credit reports.

Comments on HHS Request for Information: Voluntary Storage of Personal Data in Preparation for Emergencies


The notion of a 21st Century vault for storing personal data for emergency use has a great deal of initial appeal. However, just below the surface lurk multiple concerns about the ability of any existing system -- or even one that could be constructed -- to ensure the public has adequate data privacy and security.

Comments to the FTC on Accuracy in Background Checks and Insurance Reports


The FTC should separately undertake a review of inaccuracies in employment reports and insurance claims reports.  From our experience, job applicants and employees encounter significant problems when an erroneous criminal history is reported to an employer. Local, state and federal court records are public records that are available to anyone and are not compiled for the purpose of furnishing data to consumer reporting agencies.

Prohibit Debt Collectors from Calling Cell Phones: Comments to the FCC


The Privacy Rights Clearinghouse (PRC)1 appreciates the opportunity to comment, opposing ACA International's (ACA)2 Petition. The ACA asks the Federal Communications Commission (FCC or Commission) to exempt debt collectors from cell phone privacy rules adopted under the Telephone Consumer Protection Act (TCPA).3 We urge the Commission to deny this Petition.

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