Internet Lawyer Blog
Introduction
On December 1, 2010, the Federal Trade Commission (“FTC”) released its highly anticipated consumer privacy protection framework titled “Protecting Consumer Privacy in an Era of Rapid Change” (“Privacy Report”). A copy of the Privacy Report may be obtained on the FTC website: http://www.ftc.gov/os/2010/12/101201privacyreport.pdf. The FTC seeks public comment on the proposed privacy framework by January 31, 2011.
The proposed privacy framework has three major components: (1) privacy by design; (2) expansion of consumer choices about how companies collect and use consumer information; and (3) increased transparency of data collection practices. All three components have already ignited a lively debate among consumer advocates, businesses, advertisers and policy makers. Although, stated as tasks that a company “should do,” there is worry the FTC could take steps to use its enforcement powers against a non-compliant company.