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.