Multistakeholder Process To Develop Consumer Data Privacy Codes of Conduct, 13098-13101 [2012-5220]
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Background
[Docket No. 120214135–2135–01]
RIN 0660–XA27
Multistakeholder Process To Develop
Consumer Data Privacy Codes of
Conduct
National Telecommunications
and Information Administration, U.S.
Department of Commerce.
ACTION: Request for public comments.
AGENCY:
The National
Telecommunications and Information
Administration (NTIA) is requesting
comment on substantive consumer data
privacy issues that warrant the
development of legally enforceable
codes of conduct, as well as procedures
to foster the development of these
codes. NTIA invites public comment on
these issues from all stakeholders with
an interest in consumer data privacy,
including the commercial, academic
and civil society sectors, and from
federal and state enforcement agencies.
DATES: Comments are due on or before
5 p.m. Eastern Daylight Savings Time on
March 26, 2012.
ADDRESSES: Written comments may be
submitted by email to
privacyrfc2012@ntia.doc.gov. Comments
submitted by email should be machinesearchable and should not be copyprotected. Written comments also may
be submitted by mail to 1401
Constitution Avenue NW., Room 4725,
Washington, DC 20230. Responders
should include the name of the person
or organization filing the comment, as
well as a page number, on each page of
their submissions. All comments
received are a part of the public record
and will generally be posted to https://
www.ntia.doc.gov/category/internetpolicy-task-force without change. All
personal identifying information (for
example, name, address, etc.)
voluntarily submitted by the commenter
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SUMMARY:
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The Executive Office of the President
released Consumer Data Privacy in a
Networked World: A Framework for
Protecting Privacy and Promoting
Innovation in the Global Digital
Economy (the ‘‘Privacy and Innovation
Blueprint’’) on February 23, 2012. Two
central elements of the Privacy and
Innovation Blueprint are: (1) A
Consumer Privacy Bill of Rights, which
is a set of principles the Administration
believes should govern the handling of
personal data in commercial sectors that
are not subject to existing Federal
privacy statutes; and (2) a
multistakeholder process, which NTIA
will convene, to develop legally
enforceable codes of conduct that
specify how the Consumer Privacy Bill
of Rights applies in specific business
contexts.
These discussions will be open to
participation by all interested
stakeholders, transparent, and
consensus-driven.1 Open participation
is necessary to ensure that codes of
conduct reflect input from the broad
array of stakeholders that have interests
in putting the Consumer Privacy Bill of
Rights into practice. Any person or
organization may choose to participate,
no one is under an obligation to
participate once discussions have
started, and NTIA anticipates that there
will be opportunities to join a process
once it is underway. Transparency is
necessary to allow those who do not
participate in the process to understand
1 Privacy and Innovation Blueprint at 2, available
at https://www.whitehouse.gov/sites/default/files/
privacy-final.pdf (proposing a privacy
multistakeholder process that consists of ‘‘open,
transparent forums in which stakeholders who
share an interest in specific markets or business
contexts will work toward consensus on
appropriate, legally enforceable codes of conduct’’);
id. at 23–25, 37 (discussing importance of
consensus in multistakeholder processes that
develop Internet policy and standards).
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how participants reached their
decisions. Consensus of a broad set of
stakeholders, achieved through a
transparent process, will lend
legitimacy to the code of conduct. At the
same time, consensus will encourage
companies to adopt codes of conduct;
the decision to adopt a code of conduct
is voluntary, and companies are
unlikely to adopt a code about which
they have serious reservations.2
The privacy multistakeholder process
is voluntary. A code of conduct will not
be binding on a company unless and
until that company affirmatively
commits to follow it. NTIA expects that
a company’s public commitment to
follow a code of conduct will be legally
enforceable, provided the company is
subject to the Federal Trade
Commission’s jurisdiction.3 Enforceable
codes of conduct based on the
principles set forth in the Consumer
Privacy Bill of Rights will provide
consumers clear, understandable
baseline protections and give businesses
greater certainty about how agreed upon
privacy principles apply to them.
Companies will build consumer trust by
engaging directly with consumers and
other stakeholders during the process
and adopting a code of conduct that
stakeholders develop through this
process.4 Moreover, in any enforcement
action based on conduct covered by a
code, the FTC would likely consider a
company’s adherence to such a code
favorably.5
NTIA’s role in the privacy
multistakeholder process will be to
provide a forum for discussion and
consensus-building among stakeholders.
In situations in which stakeholders
disagree over how best to interpret the
Consumer Privacy Bill of Rights, NTIA’s
role, as explained in the Privacy and
Innovation Blueprint, ‘‘will be to help
the parties reach clarity on what their
positions are and whether there are
options for compromise toward
consensus, rather than substituting its
own judgment.’’ 6 Furthermore,
stakeholder groups convened to develop
codes of conduct will not be advisory
committees, as neither NTIA nor any
other Federal agency or office will seek
consensus advice or recommendations
2 See Privacy and Innovation Blueprint at 23–24,
37 (discussing importance of consensus in
multistakeholder processes).
3 Currently, the Federal Trade Commission (FTC)
brings cases based on violations of a company’s
public commitments in its privacy statements under
the FTC’s authority to prevent deceptive acts or
practices. See 15 U.S.C. 45. A code of conduct
developed through a multistakeholder process
likely would be enforceable under this authority.
4 Privacy and Innovation Blueprint at 24.
5 Id.
6 Id. at 27.
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on policy issues from participants in
these privacy multistakeholder
processes.7
Request for Comment
Consumer Data Privacy Issues To
Address Through Enforceable Codes of
Conduct
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NTIA plans to facilitate the
development of enforceable codes of
conduct that implement the full
Consumer Privacy Bill of Rights.
Initially, NTIA seeks to conduct a
privacy multistakeholder process
focused on a definable area where
consumers and businesses will receive
the greatest benefit in a reasonable
timeframe. Areas of consumer data
privacy in which stakeholders have
begun to collaborate to develop
practices, or to develop consensus
around specific practices, could provide
such a starting point. For example,
commenters on the Department of
Commerce’s ‘‘Privacy and Innovation
Green Paper’’ 8 were in broad agreement
that transparency is a key element of
protecting consumers’ privacy. An
initial privacy multistakeholder process
could focus on the Privacy and
Innovation Blueprint’s call to give
consumers ‘‘easily understandable and
accessible information about privacy
and security practices’’ in a particular
business setting.9 Future iterations of
the process could build on this initial
work toward a comprehensive,
enforceable code of conduct for that
setting.
7 See id. at 24 (stating that ‘‘the stakeholders
themselves will control the process and its results’’
and ‘‘[t]here is no Federal regulation at the end of
the process’’). Because participants will not provide
‘‘advice or recommendations’’ as a group to the
Federal Government, the multistakeholder
processes discussed here should not be subject to
the Federal Advisory Committee Act, 5. U.S.C. App.
2. See id. § 3(2) (defining ‘‘advisory committee’’ to
include the establishment or utilization of a group
‘‘in the interest of obtaining advice or
recommendations for the President or one or more
agencies or officers of the Federal Government,’’
subject to certain exceptions).
8 Department of Commerce, Commercial Data
Privacy and Innovation in the Internet Economy: A
Dynamic Policy Framework, Dec. 16, 2010, https://
www.ntia.doc.gov/reports/2010/IPTF_Privacy_
GreenPaper_12162010.pdf.
9 The full statement of the Transparency principle
in the Consumer Privacy Bill of Rights is as follows:
Transparency: Consumers have a right to easily
understandable and accessible information about
privacy and security practices. At times and in
places that are most useful to enabling consumers
to gain a meaningful understanding of privacy risks
and the ability to exercise Individual Control,
companies should provide clear descriptions of
what personal data they collect, why they need the
data, how they will use it, when they will delete
the data or de-identify it from consumers, and
whether and for what purposes they may share
personal data with third parties.
Privacy and Innovation Blueprint at 14.
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To identify potential consumer data
privacy topics that would benefit from
a multistakeholder process as well as
risks and concerns, NTIA seeks
comment from stakeholders.
1. NTIA seeks comment on what
issues should be addressed through the
privacy multistakeholder process.
Among a variety of alternatives, NTIA is
considering convening an initial
multistakeholder process to facilitate
the implementation of the Transparency
principle in the privacy notices for
mobile device applications (‘‘mobile
apps’’). Mobile apps are gaining in
social and economic importance.10
However, as several commenters on the
Privacy and Innovation Green Paper
noted, mobile devices pose distinct
consumer data privacy issues, such as
disclosing relevant information about
personal data practices on a small
display.11 Moreover, practices
surrounding the disclosure of consumer
data privacy practices do not appear to
have kept pace with these rapid
developments in technology and
business models. Recent studies found
that 33 percent of the top 10 paid
mobile apps for three major mobile
phone operating systems (thus, a total of
30 paid apps were studied), and 66
percent of the top 10 free mobile apps
for the same operating systems, have
privacy policies,12 while a broader
study found that only 19 percent of free
mobile apps have a link to a privacy
policy.13 With respect to apps directed
10 A recent report that summarizes current app
economy data is Gartner, Inc., Gartner Says
Worldwide Mobile Application Store Revenue
Forecast to Surpass $15 Billion in 2011, Jan. 26,
2011, https://www.gartner.com/it/
page.jsp?id=1529214; Il-Horn Hann, Siva
Viswanathan, and Byungwan Koh, The Facebook
App Economy, Sept. 19, 2011, https://www.rhsmith.
umd.edu/digits/pdfs_docs/research/2011/
AppEconomyImpact091911.pdf (estimating that
‘‘employment impact of developers building apps
on the Facebook Platform in the United States in
2011 is 182,744 full time jobs’’ and ‘‘the total
employment value of Facebook’s app economy is
$12.19 billion’’).
11 See, e.g., Ann Cavoukian, Ph.D., Comment on
the Privacy and Innovation Green Paper, at 5, Jan.
27, 2011; Center for Democracy & Technology
Comment on the Privacy and Innovation Green
Paper, at 10, Jan. 28, 2011; CTIA—The Wireless
Association Comment on the Privacy and
Innovation Green Paper, at 4, Jan. 28, 2011; TRUSTe
Comment on the Privacy and Innovation Green
Paper, at 8, Jan. 28, 2011.
12 See Future of Privacy Forum, FPF Survey: Free
Mobile Apps Better than Paid on Privacy Policies,
Dec. 19, 2011, https://www.futureofprivacy.org/
2011/12/19/fpf-survey-finds-free-mobile-appsbetter-than-paid-on-privacy-policies/(reporting on a
study of paid apps conducted in May 2011 and a
study of free apps conducted in December 2011).
13 TRUSTe, More Consumers Say Privacy—Over
Security—is Biggest Concern When Using Mobile
Applications on Smartphones, Apr. 27, 2011
(reporting results of survey of top 340 free mobile
apps conducted jointly with Harris Interactive),
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at children, a recent FTC report found
that parents generally cannot determine
which app poses privacy risks to their
children before downloading an app.14
A common set of practices that
implement the Transparency principle
in the Consumer Privacy Bill of Rights
could provide guidance to mobile apps
developers, operating systems, and apps
stores, as well as better inform
consumers about how mobile apps use
personal data. An NTIA-convened effort
toward this end could build on initial
efforts to develop codes of conduct and
best practices for mobile apps and
devices 15 and complement recent
commitments by mobile device platform
providers to promote transparency in
the mobile arena.16
NTIA seeks comment on other
potential topics, including:
• Other issues associated with mobile
apps in general (e.g., a code of conduct
that implements the full Consumer
Privacy Bill of Rights)
• Mobile apps that provide locationbased services
• Cloud computing services, i.e.,
those that store data in architectures
that provide on-demand self-service,
broad network access, resource pooling,
rapid elasticity, and measured
https://www.truste.com/blog/2011/04/27/surveyresults-are-in-consumers-say-privacy-is-a-biggerconcern-than-security-on-smartphones/.
14 See, e.g., FTC, Mobile Apps for Kids: Current
Privacy Disclosures are Disappointing (staff report),
at 17, available at https://www.ftc.gov/os/2012/02/
120216mobile_apps_kids.pdf.
15 See, e.g., CTIA, Best Practices and Guidelines
for Location Based Services, available at https://
www.ctia.org/business_resources/wic/index.cfm/
AID/11300 (last visited Jan. 18, 2012); Future of
Privacy Forum and Center for Democracy &
Technology, Best Practices for Mobile Applications
Developers, available at https://
www.futureofprivacy.org/wp-content/uploads/
Apps-Best-Practices-v-beta.pdf (last visited Jan. 18,
2012); GSMA, Mobile and Privacy: Privacy Design
Guidelines for Mobile Application Development,
Feb. 2012, available at https://www.gsma.com/go/
download/?file=gsmaprivacydesignguide
linesformobileapplicationdevelopmentv1.pdf;
Mobile Marketing Association, Global Code of
Conduct, July 15, 2008, available at https://
mmaglobal.com/codeofconduct.pdf; PrivacyChoice,
Mobile Policymaker, https://privacychoice.org/
resources/policymaker (last visited Jan. 18, 2012).
In addition, the Federal Trade Commission (FTC)
has called for stakeholders to ‘‘identify the best
means and place for conveying data practices in
plain language and in easily accessible ways on the
small screens of mobile devices.’’ FTC, Mobile Apps
for Kids: Current Privacy Disclosures are
Disappointing, supra note 14, at 3. See also FTC,
FTC Seeks Input to Revising its Guidance to
Business About Disclosures in Online, May 26,
2011, available at https://www.ftc.gov/opa/2011/05/
dotcom.shtm.
16 See California Office of the Attorney General et
al., Joint Statement of Principles, Feb. 22, 2012,
https://ag.ca.gov/cms_attachments/press/pdfs/
n2630_signed_agreement.pdf.
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Federal Register / Vol. 77, No. 43 / Monday, March 5, 2012 / Notices
service; 17 or specific cloud computing
market segments
• Accountability mechanisms (to
enable companies to demonstrate how
they are implementing the Consumer
Privacy Bill of Rights)
• Online services directed toward
teenagers (individuals 13 or older and
younger than 18)
• Online services directed toward
children (individuals under 13 years
old) 18
• Trusted identity systems, such as
those discussed in the National Strategy
for Trusted Identities in Cyberspace 19
• The use of multiple technologies,
e.g., browser cookies, local shared
objects, and browser cache, to collect
personal data
This list is not exhaustive, and NTIA
welcomes comments on any of these
topics as well as descriptions of other
topics that commenters would like
NTIA to consider for the privacy
multistakeholder process.
2. Please comment on what factors
should be considered in selecting issues
for the privacy multistakeholder
process.
Implementing the Multistakeholder
Process
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Commenters also may wish to provide
their views on how stakeholder
discussions of the proposed issue(s)
should be structured to ensure
openness, transparency, and consensusbuilding. Analogies to other Internetrelated multistakeholder processes,
whether they are concerned with policy
or technical issues, could be especially
valuable.20 Possible subjects for
comment include:
17 See Peter Mell and Tim Gance, The NIST
Definition of Cloud Computing, version 15, Oct. 7,
2009, https://csrc.nist.gov/groups/SNS/cloudcomputing/cloud-def-v15.doc (characterizing cloud
computing with these five characteristics).
18 A privacy multistakeholder process could
extend protections required of online services
directed toward children under 13 years old under
the Children’s Online Privacy Protection Act of
1998 (COPPA), 15 U.S.C. 6501–6506. The FTC’s
COPPA Rule can be found at 16 CFR Part 312.
19 Executive Office of the President, National
Strategy for Trusted Identities in Cyberspace:
Enhancing Online Choice, Efficiency, Security, and
Privacy, Apr. 2011, https://www.whitehouse.gov/
sites/default/files/rss_viewer/
NSTICstrategy_041511.pdf.
20 Potentially relevant examples mentioned in the
Privacy and Innovation Blueprint include the
Internet Corporation for Assigned Names and
Numbers (ICANN), the Internet Engineering Task
Force (IETF), and the World Wide Web Consortium
(W3C). Privacy and Innovation Blueprint at 25. The
Internet Governance Forum (IGF) is another
potentially relevant multistakeholder forum for
Internet policy development. See Internet
Governance Forum, The Internet Governance
Forum, https://www.intgovforum.org/cms/ (last
visited Feb. 3, 2012). NTIA welcomes discussion of
these and any other examples of multistakeholder
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Open Participation
The Privacy and Innovation Blueprint
calls for a code of conduct development
process that is open to any interested
participant. A broad array of
perspectives and expertise will be
necessary to ensure that the privacy
multistakeholder process thoroughly
addresses the issues before it. NTIA, as
convener of the privacy
multistakeholder process, will not set
criteria that prospective participants
must meet, such as their ability to
represent specific industries or
consumer interests. Nonetheless, there
may be practical obstacles to such broad
participation. For example, the time
required to participate and the expense
of attending in-person meetings may
make it difficult for some stakeholders
to participate. The following questions
seek input on how NTIA can keep these
barriers to a minimum and ensure that
the privacy multistakeholder process is
open, as a practical matter, to all
interested stakeholders.
3. How can NTIA promote
participation by a broad range of
stakeholders, i.e., from industry, civil
society, academia, law enforcement
agencies, and international partners?
4. Which stakeholders should
participate? What kinds of expertise or
perspectives should participants have?
5. How can NTIA best ensure the
process is inclusive, given that
participants will likely have different
levels of resources available to support
their participation?
6. Are pre-requisites for participating
in the privacy multistakeholder process
consistent with the principle of
openness? For example, what impact
would a requirement to submit a brief
position paper in advance of a
stakeholder meeting have on
participation?
7. What balance should NTIA seek to
achieve between in-person and virtual
meetings?
Transparency
Providing timely, relevant
information in an accessible manner is
crucial to effective transparency.21
Transparency, in turn, will enable all
stakeholders to understand how
policy development processes that commenters
believe are relevant to developing privacy-related
codes of conduct.
21 See Memorandum for the Heads of Executive
Departments and Agencies, Open Government
Directive, Dec. 8, 2009, available at https://
www.whitehouse.gov/open/documents/opengovernment-directive; Memorandum for the Heads
of Executive Departments and Agencies,
‘‘Transparency and Open Government,’’ Jan. 21,
2009, available at https://www.whitehouse.gov/
the_press_office/
TransparencyandOpenGovernment/.
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decisions within the privacy
multistakeholder process are reached,
whether they participate in the process
or not.
8. Which technologies could facilitate
discussions among stakeholders before,
during, and after in-person meetings?
9. How should discussions during
meetings be memorialized and
published? Are verbatim transcripts or
full recordings necessary, or would a
more abbreviated record be appropriate?
10. How can NTIA facilitate broad
public review of codes of conduct
during their development?
11. What procedures should
stakeholders follow to explain their
decisions on issues discussed within the
privacy multistakeholder process?
12. What procedures should
stakeholders follow to explain decisions
they reach in concert with other
stakeholders?
Building Consensus
Ideally, stakeholders who decide to
help develop an enforceable code of
conduct will do so with a ‘‘willingness
to work in good faith toward reaching
consensus on the code’s provisions.’’ 22
Consensus, however, does not have a
single definition. The obstacles to
consensus are also likely to vary, based
in part on how consensus is defined.
NTIA seeks comments on how other
multistakeholder processes in the
Internet policy and standards realms
have defined and reached (or failed to
reach) consensus.
13. Are there lessons from existing
consensus-based, multistakeholder
processes in the realms of Internet
policy or technical standard-setting that
could be applied to the privacy
multistakeholder process? If so, what
are they? How do they apply?
14. How did those groups define
consensus? What factors were important
in bringing such groups to consensus?
15. Are there multistakeholder efforts
that have failed to achieve consensus?
Why did these efforts fail to reach
consensus? What policies or standards,
if any, resulted from these efforts?
16. In what ways could NTIA
encourage stakeholders to reach
consensus? Under what circumstances
should NTIA facilitate discussions
among sub-groups of stakeholders to
help them reach consensus? In these
cases, what measures would be
necessary to keep the overall process
transparent?
Response to this Request for Public
Comments is voluntary. Commenters are
free to address any or all of the issues
identified above, as well as provide
22 Privacy
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and Innovation Blueprint at 26.
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information on other topics that they
think are relevant to developing policies
consistent with open, transparent,
voluntary, consensus-based processes
for developing consumer data privacy
codes of conduct. Please note that the
Government will not pay for response
preparation or for the use of any
information contained in the response.
Dated: February 29, 2012.
Lawrence E. Strickling,
Assistant Secretary for Communications and
Information.
[FR Doc. 2012–5220 Filed 3–2–12; 8:45 am]
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13101
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Estimated Respondents or
Recordkeepers per Year: .33.
Estimated Reports Annually per
Respondent or Recordkeeper: 1.
Estimated Hours per Response: 2.
Estimated Total Hours per Year: .67.
Rule 190.02(b)(1)
Estimated Respondents or
Recordkeepers per Year: .33.
Estimated Reports Annually per
Respondent or Recordkeeper: 4.
Estimated Hours per Response: 1.
Estimated Total Hours per Year: 1.32.
Rule 190.02(b)(2)
Estimated Respondents or
Recordkeepers per Year: .33.
Estimated Reports Annually per
Respondent or Recordkeeper: 10,000.
Estimated Hours per Response: .1.
Estimated Total Hours per Year: 330.
Rule 190.02(b)(3)
Estimated Respondents or
Recordkeepers per Year: .05 (rarely if
ever occurs).
Estimated Reports Annually per
Respondent or Recordkeeper: 10,000.
Estimated Hours per Response: .2.
Estimated Total Hours per Year: 100.
Rule 190.02(b)(4)
Estimated Respondents or
Recordkeepers per Year: .33.
Estimated Reports Annually per
Respondent or Recordkeeper: 10,000.
Estimated Hours per Response: .2.
Estimated Total Hours per Year: 660.
Rule 190.02(c)
Estimated Respondents or
Recordkeepers per Year: .33.
Estimated Reports Annually per
Respondent or Recordkeeper: 10.
Estimated Hours per Response: 10.
Estimated Total Hours per Year: 33.
Rule 190.03(a)(1)
Estimated Respondents or
Recordkeepers per Year: .33.
E:\FR\FM\05MRN1.SGM
05MRN1
Agencies
[Federal Register Volume 77, Number 43 (Monday, March 5, 2012)]
[Notices]
[Pages 13098-13101]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2012-5220]
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DEPARTMENT OF COMMERCE
National Telecommunications and Information Administration
[Docket No. 120214135-2135-01]
RIN 0660-XA27
Multistakeholder Process To Develop Consumer Data Privacy Codes
of Conduct
AGENCY: National Telecommunications and Information Administration,
U.S. Department of Commerce.
ACTION: Request for public comments.
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SUMMARY: The National Telecommunications and Information Administration
(NTIA) is requesting comment on substantive consumer data privacy
issues that warrant the development of legally enforceable codes of
conduct, as well as procedures to foster the development of these
codes. NTIA invites public comment on these issues from all
stakeholders with an interest in consumer data privacy, including the
commercial, academic and civil society sectors, and from federal and
state enforcement agencies.
DATES: Comments are due on or before 5 p.m. Eastern Daylight Savings
Time on March 26, 2012.
ADDRESSES: Written comments may be submitted by email to
privacyrfc2012@ntia.doc.gov. Comments submitted by email should be
machine-searchable and should not be copy-protected. Written comments
also may be submitted by mail to 1401 Constitution Avenue NW., Room
4725, Washington, DC 20230. Responders should include the name of the
person or organization filing the comment, as well as a page number, on
each page of their submissions. All comments received are a part of the
public record and will generally be posted to https://www.ntia.doc.gov/category/internet-policy-task-force without change. All personal
identifying information (for example, name, address, etc.) voluntarily
submitted by the commenter may be publicly accessible. Do not submit
Confidential Business Information or otherwise sensitive or protected
information. NTIA will accept anonymous comments (enter ``N/A'' in the
required fields if you wish to remain anonymous).
FOR FURTHER INFORMATION CONTACT: Aaron Burstein, National
Telecommunications and Information Administration, U.S. Department of
Commerce, 1401 Constitution Avenue NW., Room 4725, Washington, DC
20230; telephone (202) 482-1055; email aburstein@ntia.doc.gov. Please
direct media inquiries to NTIA's Office of Public Affairs, (202) 482-
7002.
SUPPLEMENTARY INFORMATION:
Background
The Executive Office of the President released Consumer Data
Privacy in a Networked World: A Framework for Protecting Privacy and
Promoting Innovation in the Global Digital Economy (the ``Privacy and
Innovation Blueprint'') on February 23, 2012. Two central elements of
the Privacy and Innovation Blueprint are: (1) A Consumer Privacy Bill
of Rights, which is a set of principles the Administration believes
should govern the handling of personal data in commercial sectors that
are not subject to existing Federal privacy statutes; and (2) a
multistakeholder process, which NTIA will convene, to develop legally
enforceable codes of conduct that specify how the Consumer Privacy Bill
of Rights applies in specific business contexts.
These discussions will be open to participation by all interested
stakeholders, transparent, and consensus-driven.\1\ Open participation
is necessary to ensure that codes of conduct reflect input from the
broad array of stakeholders that have interests in putting the Consumer
Privacy Bill of Rights into practice. Any person or organization may
choose to participate, no one is under an obligation to participate
once discussions have started, and NTIA anticipates that there will be
opportunities to join a process once it is underway. Transparency is
necessary to allow those who do not participate in the process to
understand how participants reached their decisions. Consensus of a
broad set of stakeholders, achieved through a transparent process, will
lend legitimacy to the code of conduct. At the same time, consensus
will encourage companies to adopt codes of conduct; the decision to
adopt a code of conduct is voluntary, and companies are unlikely to
adopt a code about which they have serious reservations.\2\
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\1\ Privacy and Innovation Blueprint at 2, available at https://www.whitehouse.gov/sites/default/files/privacy-final.pdf (proposing
a privacy multistakeholder process that consists of ``open,
transparent forums in which stakeholders who share an interest in
specific markets or business contexts will work toward consensus on
appropriate, legally enforceable codes of conduct''); id. at 23-25,
37 (discussing importance of consensus in multistakeholder processes
that develop Internet policy and standards).
\2\ See Privacy and Innovation Blueprint at 23-24, 37
(discussing importance of consensus in multistakeholder processes).
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The privacy multistakeholder process is voluntary. A code of
conduct will not be binding on a company unless and until that company
affirmatively commits to follow it. NTIA expects that a company's
public commitment to follow a code of conduct will be legally
enforceable, provided the company is subject to the Federal Trade
Commission's jurisdiction.\3\ Enforceable codes of conduct based on the
principles set forth in the Consumer Privacy Bill of Rights will
provide consumers clear, understandable baseline protections and give
businesses greater certainty about how agreed upon privacy principles
apply to them. Companies will build consumer trust by engaging directly
with consumers and other stakeholders during the process and adopting a
code of conduct that stakeholders develop through this process.\4\
Moreover, in any enforcement action based on conduct covered by a code,
the FTC would likely consider a company's adherence to such a code
favorably.\5\
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\3\ Currently, the Federal Trade Commission (FTC) brings cases
based on violations of a company's public commitments in its privacy
statements under the FTC's authority to prevent deceptive acts or
practices. See 15 U.S.C. 45. A code of conduct developed through a
multistakeholder process likely would be enforceable under this
authority.
\4\ Privacy and Innovation Blueprint at 24.
\5\ Id.
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NTIA's role in the privacy multistakeholder process will be to
provide a forum for discussion and consensus-building among
stakeholders. In situations in which stakeholders disagree over how
best to interpret the Consumer Privacy Bill of Rights, NTIA's role, as
explained in the Privacy and Innovation Blueprint, ``will be to help
the parties reach clarity on what their positions are and whether there
are options for compromise toward consensus, rather than substituting
its own judgment.'' \6\ Furthermore, stakeholder groups convened to
develop codes of conduct will not be advisory committees, as neither
NTIA nor any other Federal agency or office will seek consensus advice
or recommendations
[[Page 13099]]
on policy issues from participants in these privacy multistakeholder
processes.\7\
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\6\ Id. at 27.
\7\ See id. at 24 (stating that ``the stakeholders themselves
will control the process and its results'' and ``[t]here is no
Federal regulation at the end of the process''). Because
participants will not provide ``advice or recommendations'' as a
group to the Federal Government, the multistakeholder processes
discussed here should not be subject to the Federal Advisory
Committee Act, 5. U.S.C. App. 2. See id. Sec. 3(2) (defining
``advisory committee'' to include the establishment or utilization
of a group ``in the interest of obtaining advice or recommendations
for the President or one or more agencies or officers of the Federal
Government,'' subject to certain exceptions).
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Request for Comment
Consumer Data Privacy Issues To Address Through Enforceable Codes of
Conduct
NTIA plans to facilitate the development of enforceable codes of
conduct that implement the full Consumer Privacy Bill of Rights.
Initially, NTIA seeks to conduct a privacy multistakeholder process
focused on a definable area where consumers and businesses will receive
the greatest benefit in a reasonable timeframe. Areas of consumer data
privacy in which stakeholders have begun to collaborate to develop
practices, or to develop consensus around specific practices, could
provide such a starting point. For example, commenters on the
Department of Commerce's ``Privacy and Innovation Green Paper'' \8\
were in broad agreement that transparency is a key element of
protecting consumers' privacy. An initial privacy multistakeholder
process could focus on the Privacy and Innovation Blueprint's call to
give consumers ``easily understandable and accessible information about
privacy and security practices'' in a particular business setting.\9\
Future iterations of the process could build on this initial work
toward a comprehensive, enforceable code of conduct for that setting.
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\8\ Department of Commerce, Commercial Data Privacy and
Innovation in the Internet Economy: A Dynamic Policy Framework, Dec.
16, 2010, https://www.ntia.doc.gov/reports/2010/IPTF_Privacy_GreenPaper_12162010.pdf.
\9\ The full statement of the Transparency principle in the
Consumer Privacy Bill of Rights is as follows:
Transparency: Consumers have a right to easily understandable
and accessible information about privacy and security practices. At
times and in places that are most useful to enabling consumers to
gain a meaningful understanding of privacy risks and the ability to
exercise Individual Control, companies should provide clear
descriptions of what personal data they collect, why they need the
data, how they will use it, when they will delete the data or de-
identify it from consumers, and whether and for what purposes they
may share personal data with third parties.
Privacy and Innovation Blueprint at 14.
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To identify potential consumer data privacy topics that would
benefit from a multistakeholder process as well as risks and concerns,
NTIA seeks comment from stakeholders.
1. NTIA seeks comment on what issues should be addressed through
the privacy multistakeholder process. Among a variety of alternatives,
NTIA is considering convening an initial multistakeholder process to
facilitate the implementation of the Transparency principle in the
privacy notices for mobile device applications (``mobile apps'').
Mobile apps are gaining in social and economic importance.\10\ However,
as several commenters on the Privacy and Innovation Green Paper noted,
mobile devices pose distinct consumer data privacy issues, such as
disclosing relevant information about personal data practices on a
small display.\11\ Moreover, practices surrounding the disclosure of
consumer data privacy practices do not appear to have kept pace with
these rapid developments in technology and business models. Recent
studies found that 33 percent of the top 10 paid mobile apps for three
major mobile phone operating systems (thus, a total of 30 paid apps
were studied), and 66 percent of the top 10 free mobile apps for the
same operating systems, have privacy policies,\12\ while a broader
study found that only 19 percent of free mobile apps have a link to a
privacy policy.\13\ With respect to apps directed at children, a recent
FTC report found that parents generally cannot determine which app
poses privacy risks to their children before downloading an app.\14\ A
common set of practices that implement the Transparency principle in
the Consumer Privacy Bill of Rights could provide guidance to mobile
apps developers, operating systems, and apps stores, as well as better
inform consumers about how mobile apps use personal data. An NTIA-
convened effort toward this end could build on initial efforts to
develop codes of conduct and best practices for mobile apps and devices
\15\ and complement recent commitments by mobile device platform
providers to promote transparency in the mobile arena.\16\
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\10\ A recent report that summarizes current app economy data is
Gartner, Inc., Gartner Says Worldwide Mobile Application Store
Revenue Forecast to Surpass $15 Billion in 2011, Jan. 26, 2011,
https://www.gartner.com/it/page.jsp?id=1529214; Il-Horn Hann, Siva
Viswanathan, and Byungwan Koh, The Facebook App Economy, Sept. 19,
2011, https://www.rhsmith.umd.edu/digits/pdfs_docs/research/2011/AppEconomyImpact091911.pdf (estimating that ``employment impact of
developers building apps on the Facebook Platform in the United
States in 2011 is 182,744 full time jobs'' and ``the total
employment value of Facebook's app economy is $12.19 billion'').
\11\ See, e.g., Ann Cavoukian, Ph.D., Comment on the Privacy and
Innovation Green Paper, at 5, Jan. 27, 2011; Center for Democracy &
Technology Comment on the Privacy and Innovation Green Paper, at 10,
Jan. 28, 2011; CTIA--The Wireless Association Comment on the Privacy
and Innovation Green Paper, at 4, Jan. 28, 2011; TRUSTe Comment on
the Privacy and Innovation Green Paper, at 8, Jan. 28, 2011.
\12\ See Future of Privacy Forum, FPF Survey: Free Mobile Apps
Better than Paid on Privacy Policies, Dec. 19, 2011, https://www.futureofprivacy.org/2011/12/19/fpf-survey-finds-free-mobile-apps-better-than-paid-on-privacy-policies/(reporting on a study of
paid apps conducted in May 2011 and a study of free apps conducted
in December 2011).
\13\ TRUSTe, More Consumers Say Privacy--Over Security--is
Biggest Concern When Using Mobile Applications on Smartphones, Apr.
27, 2011 (reporting results of survey of top 340 free mobile apps
conducted jointly with Harris Interactive), https://www.truste.com/blog/2011/04/27/survey-results-are-in-consumers-say-privacy-is-a-bigger-concern-than-security-on-smartphones/.
\14\ See, e.g., FTC, Mobile Apps for Kids: Current Privacy
Disclosures are Disappointing (staff report), at 17, available at
https://www.ftc.gov/os/2012/02/120216mobile_apps_kids.pdf.
\15\ See, e.g., CTIA, Best Practices and Guidelines for Location
Based Services, available at https://www.ctia.org/business_resources/wic/index.cfm/AID/11300 (last visited Jan. 18, 2012);
Future of Privacy Forum and Center for Democracy & Technology, Best
Practices for Mobile Applications Developers, available at https://www.futureofprivacy.org/wp-content/uploads/Apps-Best-Practices-v-beta.pdf (last visited Jan. 18, 2012); GSMA, Mobile and Privacy:
Privacy Design Guidelines for Mobile Application Development, Feb.
2012, available at https://www.gsma.com/go/download/?file=gsmaprivacydesignguidelinesformobileapplicationdevelopmentv1.pdf; Mobile Marketing Association, Global Code of Conduct, July 15,
2008, available at https://mmaglobal.com/codeofconduct.pdf;
PrivacyChoice, Mobile Policymaker, https://privacychoice.org/resources/policymaker (last visited Jan. 18, 2012). In addition, the
Federal Trade Commission (FTC) has called for stakeholders to
``identify the best means and place for conveying data practices in
plain language and in easily accessible ways on the small screens of
mobile devices.'' FTC, Mobile Apps for Kids: Current Privacy
Disclosures are Disappointing, supra note 14, at 3. See also FTC,
FTC Seeks Input to Revising its Guidance to Business About
Disclosures in Online, May 26, 2011, available at https://www.ftc.gov/opa/2011/05/dotcom.shtm.
\16\ See California Office of the Attorney General et al., Joint
Statement of Principles, Feb. 22, 2012, https://ag.ca.gov/cms_attachments/press/pdfs/n2630_signed_agreement.pdf.
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NTIA seeks comment on other potential topics, including:
Other issues associated with mobile apps in general (e.g.,
a code of conduct that implements the full Consumer Privacy Bill of
Rights)
Mobile apps that provide location-based services
Cloud computing services, i.e., those that store data in
architectures that provide on-demand self-service, broad network
access, resource pooling, rapid elasticity, and measured
[[Page 13100]]
service; \17\ or specific cloud computing market segments
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\17\ See Peter Mell and Tim Gance, The NIST Definition of Cloud
Computing, version 15, Oct. 7, 2009, https://csrc.nist.gov/groups/SNS/cloud-computing/cloud-def-v15.doc (characterizing cloud
computing with these five characteristics).
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Accountability mechanisms (to enable companies to
demonstrate how they are implementing the Consumer Privacy Bill of
Rights)
Online services directed toward teenagers (individuals 13
or older and younger than 18)
Online services directed toward children (individuals
under 13 years old) \18\
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\18\ A privacy multistakeholder process could extend protections
required of online services directed toward children under 13 years
old under the Children's Online Privacy Protection Act of 1998
(COPPA), 15 U.S.C. 6501-6506. The FTC's COPPA Rule can be found at
16 CFR Part 312.
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Trusted identity systems, such as those discussed in the
National Strategy for Trusted Identities in Cyberspace \19\
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\19\ Executive Office of the President, National Strategy for
Trusted Identities in Cyberspace: Enhancing Online Choice,
Efficiency, Security, and Privacy, Apr. 2011, https://www.whitehouse.gov/sites/default/files/rss_viewer/NSTICstrategy_041511.pdf.
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The use of multiple technologies, e.g., browser cookies,
local shared objects, and browser cache, to collect personal data
This list is not exhaustive, and NTIA welcomes comments on any of
these topics as well as descriptions of other topics that commenters
would like NTIA to consider for the privacy multistakeholder process.
2. Please comment on what factors should be considered in selecting
issues for the privacy multistakeholder process.
Implementing the Multistakeholder Process
Commenters also may wish to provide their views on how stakeholder
discussions of the proposed issue(s) should be structured to ensure
openness, transparency, and consensus-building. Analogies to other
Internet-related multistakeholder processes, whether they are concerned
with policy or technical issues, could be especially valuable.\20\
Possible subjects for comment include:
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\20\ Potentially relevant examples mentioned in the Privacy and
Innovation Blueprint include the Internet Corporation for Assigned
Names and Numbers (ICANN), the Internet Engineering Task Force
(IETF), and the World Wide Web Consortium (W3C). Privacy and
Innovation Blueprint at 25. The Internet Governance Forum (IGF) is
another potentially relevant multistakeholder forum for Internet
policy development. See Internet Governance Forum, The Internet
Governance Forum, https://www.intgovforum.org/cms/ (last visited Feb.
3, 2012). NTIA welcomes discussion of these and any other examples
of multistakeholder policy development processes that commenters
believe are relevant to developing privacy-related codes of conduct.
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Open Participation
The Privacy and Innovation Blueprint calls for a code of conduct
development process that is open to any interested participant. A broad
array of perspectives and expertise will be necessary to ensure that
the privacy multistakeholder process thoroughly addresses the issues
before it. NTIA, as convener of the privacy multistakeholder process,
will not set criteria that prospective participants must meet, such as
their ability to represent specific industries or consumer interests.
Nonetheless, there may be practical obstacles to such broad
participation. For example, the time required to participate and the
expense of attending in-person meetings may make it difficult for some
stakeholders to participate. The following questions seek input on how
NTIA can keep these barriers to a minimum and ensure that the privacy
multistakeholder process is open, as a practical matter, to all
interested stakeholders.
3. How can NTIA promote participation by a broad range of
stakeholders, i.e., from industry, civil society, academia, law
enforcement agencies, and international partners?
4. Which stakeholders should participate? What kinds of expertise
or perspectives should participants have?
5. How can NTIA best ensure the process is inclusive, given that
participants will likely have different levels of resources available
to support their participation?
6. Are pre-requisites for participating in the privacy
multistakeholder process consistent with the principle of openness? For
example, what impact would a requirement to submit a brief position
paper in advance of a stakeholder meeting have on participation?
7. What balance should NTIA seek to achieve between in-person and
virtual meetings?
Transparency
Providing timely, relevant information in an accessible manner is
crucial to effective transparency.\21\ Transparency, in turn, will
enable all stakeholders to understand how decisions within the privacy
multistakeholder process are reached, whether they participate in the
process or not.
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\21\ See Memorandum for the Heads of Executive Departments and
Agencies, Open Government Directive, Dec. 8, 2009, available at
https://www.whitehouse.gov/open/documents/open-government-directive;
Memorandum for the Heads of Executive Departments and Agencies,
``Transparency and Open Government,'' Jan. 21, 2009, available at
https://www.whitehouse.gov/the_press_office/TransparencyandOpenGovernment/.
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8. Which technologies could facilitate discussions among
stakeholders before, during, and after in-person meetings?
9. How should discussions during meetings be memorialized and
published? Are verbatim transcripts or full recordings necessary, or
would a more abbreviated record be appropriate?
10. How can NTIA facilitate broad public review of codes of conduct
during their development?
11. What procedures should stakeholders follow to explain their
decisions on issues discussed within the privacy multistakeholder
process?
12. What procedures should stakeholders follow to explain decisions
they reach in concert with other stakeholders?
Building Consensus
Ideally, stakeholders who decide to help develop an enforceable
code of conduct will do so with a ``willingness to work in good faith
toward reaching consensus on the code's provisions.'' \22\ Consensus,
however, does not have a single definition. The obstacles to consensus
are also likely to vary, based in part on how consensus is defined.
NTIA seeks comments on how other multistakeholder processes in the
Internet policy and standards realms have defined and reached (or
failed to reach) consensus.
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\22\ Privacy and Innovation Blueprint at 26.
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13. Are there lessons from existing consensus-based,
multistakeholder processes in the realms of Internet policy or
technical standard-setting that could be applied to the privacy
multistakeholder process? If so, what are they? How do they apply?
14. How did those groups define consensus? What factors were
important in bringing such groups to consensus?
15. Are there multistakeholder efforts that have failed to achieve
consensus? Why did these efforts fail to reach consensus? What policies
or standards, if any, resulted from these efforts?
16. In what ways could NTIA encourage stakeholders to reach
consensus? Under what circumstances should NTIA facilitate discussions
among sub-groups of stakeholders to help them reach consensus? In these
cases, what measures would be necessary to keep the overall process
transparent?
Response to this Request for Public Comments is voluntary.
Commenters are free to address any or all of the issues identified
above, as well as provide
[[Page 13101]]
information on other topics that they think are relevant to developing
policies consistent with open, transparent, voluntary, consensus-based
processes for developing consumer data privacy codes of conduct. Please
note that the Government will not pay for response preparation or for
the use of any information contained in the response.
Dated: February 29, 2012.
Lawrence E. Strickling,
Assistant Secretary for Communications and Information.
[FR Doc. 2012-5220 Filed 3-2-12; 8:45 am]
BILLING CODE 3510-60-P