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NAI Files Comments on Preliminary FTC Staff Privacy Report

The NAI today filed comments on the FTC Staff’s Preliminary Report, Protecting Consumer Privacy in an Era of Rapid Change: A Proposed Framework for Businesses and Policymakers. In its report, FTC Staff presented a proposed framework addressing commercial use of consumer data, and asked for comment to help guide further development and refinement of its proposal.

The NAI’s comments address FTC Staff’s questions from the perspective of the online advertising marketplace. The NAI’s comments address the substantive protections FTC Staff proposes as a baseline for consumer data falling within the scope of the framework, and how voluntary codes of conduct can implement those protections through sector-specific standards. The comments address issues posed by Staff’s proposed framework for simplified choice, including “Do Not Track.” Finally, the comments address the proposed framework’s transparency principles, including improved notice, access, and education, in the context of online advertising.

Throughout its comments, the NAI discusses how self-regulatory mechanisms can help further develop and implement the proposals set forth in FTC Staff’s proposed framework.

The NAI’s comments can be found here.

–Meredith Halama, NAI Assistant General Counsel, Policy