4A’s Comments on “Developing the Administration’s Approach to Consumer Privacy”

On Friday, November 9, 2018, the 4A’s submitted two sets of comments in response to the request for public comments on “Developing the Administration’s Approach to Consumer Privacy,” a September 26 notice by the National Telecommunications and Information Administration, a division of the U.S. Department of Commerce.

The first set of comments focuses on a high-level overview of a new privacy regulatory approach, referred to as the “New Paradigm.” This new approach seeks to set up a framework in which data practices will be evaluated on an evolving reasonableness standard that would seek to achieve a balanced approach between consumer protection and national prosperity. You can find this set of comments here.

The second set of comments focuses on the need for a strong pre-emptive federal law that sets a national standard for reasonable data practices, prohibits unreasonable data practices, and uses a risk-based approach to prevent concrete consumer harms. This second set of comments also highlights much of the good work the advertising industry has already achieved through strong, accountable self-regulatory efforts over the past 10 years. You can find this set of comments here.