Mozilla’s Comments in Response to the FTC’s Inquiry on Privacy

Last week Mozilla submitted comments to the U.S. Federal Trade Commission in response to their request for comment on a proposal describing a new framework for protecting consumer privacy in both online and offline environments. The FTC sought input on a broad range of of issues from online privacy protections for children to the blending of distinctions between PII and non-PII. More than 400 comments were submitted from a wide array of interests including  individuals, consumer groups, advocacy coalitions, advertisers, social networks and all kinds of service providers. You can see the complete list here. It’s worth reading a few of these to get a sense of the discourse (i.e. Future of Privacy Forum, Facebook, CDT, and US Chamber of Commerce)

In summary, the Mozilla comments recommended:

  • Expanding the definition of personal information to data that can be reasonably linked to a specific consumer, computer or device. The emergence of browsing history, geolocation, behavioral advertising data, browser fingerprints and the social graph are examples of personal information that warrant additional consideration to prevent unintended secondary uses.
  • Adding industry best practices, standardization and technology tools to Privacy By Design initiatives to help consumers make sense of an array of similar and confusing privacy configurations across the Web.
  • Adoption and creation of a uniform and comprehensive choice mechanism through a new Do Not Track (DNT) HTTP header as part of an evolutionary arc of privacy improvements.
  • Continued FTC leadership to develop consensus on the scope of DNT as it relates to online behavioral advertising and implementation across the online advertising industry.
  • Using contextual notices in conjunction with other enhancements, such as graphical icons, to improve online privacy policies and notices.

We expect the FTC will spend some time evaluating and organizing the feedback they received, and later this year, will issue a follow-up report with suggested next steps.

Thanks to the many, many people who contributed to the comments and in particular, Alex Fowler and Sid Stamm who led the drafting and development process.

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