In comments submitted to the National Telecommunications and Information Administration (NTIA), CFA, Consumer Action, the National Consumers League, and Privacy Rights Clearinghouse offer suggested improvements to NTIA’s privacy policy recommendations for the Trump Administration. The current proposal, with its risk-management rather than rights-based approach, does not provide an acceptable roadmap for the kind of privacy protection that Americans need.
We believe that the goal of federal action on data protection should be the adoption of public policy that requires individuals’ personal data to be treated in accordance with the basic fair information principles of collection limitation, data quality, purpose specification, use limitation, security safeguards, individual participation, and accountability. The outcomes should be strong, meaningful, and comprehensive protections to preserve civil rights, prevent unlawful discrimination, and advance equal opportunity. Data protection rights must be enforceable by governments and individuals and provide strong redress. Furthermore, federal action should not prevent the states from implementing and enforcing stronger privacy protections.