In joint comments filed with the Federal Trade Commission (FTC) in response to its December 12, 2017 workshop on “Informational Injury,” CFA and other consumer advocacy organizations bring up crucial questions about the agency’s focus on “harm” and its limited ability to regulate companies’ privacy and security practices. We believe that we need a legal framework that is based on individuals’ rights to own and control their personal information and a data protection authority that can effectively ensure that those rights are respected. Without these measures, public workshops such as this one, while interesting and informative, cannot produce the privacy and security protections that Americans need and deserve.

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