I give birth to a Privacy White Paper
Attached please find links to our exciting new White Paper "Everything You Wanted To Know About the FCC, the FTC and Privacy Except Your Eyes Kept Glazing Over."
That's not actually the official title.
As explained at length, the FTC and the FCC have enjoyed a complementary relationship in the realm of consumer protection for more than 80 years. Nor is the FCC unique in this. Indeed, the FTC generally sits at the center of a "hub and spoke" system where specialized agencies handling unique sectors of the economy (e.g., FDA, CFPB, HHS for HIPPA, numerous financial regulators, FERC (power grid), Transportation (DoT)) which require specifically tailored oversight in addition to the FTC's role.
Accordingly, while Congress should expand the FTC's powers to address the increasing threats to consumer privacy, the FCC can, and should, continue to play an important complimentary role -- beginning with the long-promised ruleamaking on broadband privacy. In accordance with the legislative intent of Section 222, the FCC must protect both consumer privacy and OTT competitors.
We conclude with some details about the current practices (and potential practices) of broadband access providers, and recommendations for the FCC's upcoming rulemaking.
Press Release on White Paper:
Direct Link to 80+ page White Paper:
I find the creative prcess this intense (I've been working on this for the last several weeks) is like giving birth. Ecept when you're finished you look down at you're adorable newborn, smile benignly, then toss it to the assembled crowd jump and say: "OK, time to make another baby."