Consumer information is at the center of our economy. It connects us to the right products and services, helps companies innovate and expand, and allows consumers to make smarter choices throughout their lives. While the use of consumer information is becoming more important to businesses and consumers, there is a growing concern among policy makers that the laws governing consumer privacy are not keeping up.
Over the last year, the FTC and the Department Commerce have been studying these issues and each released preliminary reports looking at the changing privacy landscape. Although much of the discussion has focused on online data, the reports take a broader look at the privacy practices of organizations both online and offline, offering a number of recommendations that challenge policy makers and companies to better protect consumer information.
As regulatory agencies and Congress continue to examine business practices around consumer privacy, I thought it might be helpful to take a look at recent comments Experian filed with the FTC and highlight a few areas that will be important for policy makers to consider going forward.
A flexible and adaptive regulatory system is essential to an innovative economy.
Consumer privacy expectations are continuing to evolve and, as a result, standards must not be rigid. Along with existing regulations, new challenges should be dealt with robust and evolving self-regulation – not new laws – to ensure consumers are protected now and in the future.
Consumer privacy should be viewed from multiple perspectives.
The recent debate around commercial information sharing has centered on consumer privacy; however there are other viewpoints that should be considered. For example, how are businesses using information in a responsible manner to innovate and increase productivity or how does the overall economy benefit from consumer information that makes us more competitive in a global marketplace.
Incorporating consumer privacy into all aspects of a business is a powerful consumer benefit.
The FTC report recommends a “privacy by design” framework – meaning that companies incorporate privacy into every aspect of their business operations. This framework could potentially evolve into a useful tool for companies to evaluate their privacy and data security policies.