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Public Policy

Public Policy is a key pillar of OTA, working to foster the development of policy, legislative and regulatory efforts benefiting consumers while fostering innovation in data protection, privacy, security and identity theft. OTA supports multi-stakeholder efforts to promote best practices and meaningful self-regulation . OTA members receive weekly briefings and advice to help navigate the complexities and to move from compliance mindset to one of embracing stewardship.

Federal Communications Commission (FCC)

Broadband Providers and Privacy - The FCC issued a Notice of Proposed Rule Making regarding broadband consumers and transparency and control of their data. The call for public comment requested input on issues of data control including choice, transparency and security. OTA's respose applauds the efforts to enhance consumer privacy while promoting innovation. Key elements in OTA's comments cover scope, privacy disclosures, tracking, data breach response and security.

Rate Regulation & Internet Access - proposed legislation raises issues of inhibiting the FCC’s ability to carry out its statutory consumer protection obligations. In addition, the current version creates the potential for inequity where only the wealthy can afford privacy.

  • Joint Letter opposing H.R. 2666: “No Rate Regulation of Broadband Internet Access Act” - April, 2016

National Telecommunications and Information Administration (NTIA)

Advancement of IoT - OTA is actively involved with the NTIA Internet Policy Taskforce efforts to review of the benefits, challenges, and potential roles for the government in fostering the advancement of the Internet of Things.  

 

OTA Submits Comments to IAB Draft Standards

In response to the Interactive Ad Bureau’s release of the Standard Ad Unit Portfolio Draft can call for public comments, Online Trust Alliance (OTA) submits the following comments and recommendations.  Over the past decade, OTA has worked closely with leaders in the advertising supply chain, including publishers, advertisers and ad networks to increase the trust of online advertising.  Reflecting increased consumer distain for online advertising and usage of ad blockers, OTA recently released a white paper entitled “A Vision for Trustworthy Adverting”.  In this paper OTA call

The Role of Connected Devices in Recent Cyber Attacks

“Understanding the Role of Connected Devices in Recent Cyber Attacks” statement to the US House of Representatives Committee on Energy and Commerce

Download the Paper >

Drones - Privacy Transparency & Accountability

This week a multi-stakeholder group convened by the U.S. Department of Commerce NTIA including the OTA and over 2-dozen organizations, released the "Best Practices for UAS Privacy, Transparency, and Accountably." This updated was released today in coordination with related announcements from the White House and FAA.  This document provides important guidelines for developers and operators to adopt responsible business and privacy practices, while promoting innovation.

OTA Response to NTIA IoT Request for Comments

June 1, 2016 -- OTA remains concerned about the long-term negative impact to consumer trust and confidence related to online services. Collectively the public and private sectors must move beyond a compliance mindset to becoming data stewards while respecting consumer choices and privacy. Unfortunately in all too many cases, in the rush to market, companies have disregarded these efforts resulting in a growing level of mistrust. In considering many of the questions raised in the RFC, OTA has drawn on its IoT Trust Framework -- 30 critical controls and criteria which serve as the foundation for a self-regulatory and certification program. Today, this Framework is being embraced by a wide range of organizations providing prescriptive and actionable advice for developers and service providers.....

OTA Response to FCC NPRM on Privacy and Broadband Providers

May 27, 2016 -- In response to the FCC’s Notice of Proposed Rule Making, (NPRM) to establish a set of regulations governing the data collection, use, and sharing practices of broadband Internet service providers (“Providers”), the Online Trust Alliance (OTA) submits this response. Providers have a unique role and responsibility as they have a comprehensive view of the online behavior for every home and business they serve. By focusing on Providers, the FCC has a timely opportunity to insure consumers and businesses have control over the collection, use and sharing of their personal and business data. Unlike choosing what web sites to visit, users have limited internet access options to choose from. Building and enhancing security and privacy into broadband services is critical to the resiliency of our economy and society. Left unchecked we risk chilling effects, disrupting business models, hampering the free exchange of ideas, and disproportionally disenfranchising segments of society.........

OTA Response to FCC on draft NPRM for Privacy and Broadband Providers

March 29, 2016 -- In response to your draft fact sheet and draft Notice of Proposed Rulemaking (NPRM), regarding consumer control of data collection, use and sharing by broadband providers and wireless carriers (Providers), the Online Trust Alliance (OTA) provides the following comments. By focusing on Providers, the FCC has a unique and timely opportunity to shift control back to consumers. Unlike choosing what web sites to visit, consumers have few if any broadband options. In locations where such options are available to change Providers, the barriers and costs to change can be significant.  Consumers are paying for these services and should not be also be expected to pay in perpetuity with their personal and business data.

OTA Response to NTIA StakeHolder Engagement in Cybersecurity

Collectively OTA believes multi-stakeholder efforts must be open, transparent and develop consensus by providing an equitable and fair opportunity for interested parties to participate. Processes need to be established to help keep discussions, priorities and scope from being dominated by special interest and dominate market players. We believe a facilitated led process will effectively drive the formation of best practices to allow us to improve the security, stability and resiliency of Internet. It is important to note that as the stakeholders are typically geographically diverse, meetings need to accommodate those in different time zones and promote remote participation. In addition the cost, benefits and incentives for cyber security must also be addressed and considered when developing best practices and any self-regulatory models.

How the FTC Identifies, Targets and Tracks Companies - Learn How To Keep Off Their List!

The Federal Trade Commission (FTC) utilizes consumer complaint date to help track companies and identify potential enforcement targets. OTA's webinar discusses some of the ways in which the FTC identifies its enforcement targets and focuses in particular on the FTC’s use of consumer complaint data. David Zetoony, leader of Bryan, Cave LLP's global data privacy and security practice and Scott J. Stein, Online Trust Alliance, VP of Public Policy are the presenters.

Response to Data Security & Breach Notification Act of 2015

OTA believes a single Federal law preempting the patchwork of 47 State laws will benefit consumers and business alike, by providing clarity and a single standard definition of privacy, notification requirements and reasonable security requirements. However, any federal data breach notification law must be sufficiently robust, while not unduly burdening businesses committed to protecting consumers and their data.   Consumers today are becoming jaded and risk being overwhelmed by the sheer volume of data breach notices.

Data Breach Legislation Letter To Congress

The Online Trust Alliance (OTA), a 501c3 non-profit with the mission to enhance online trust and promote innovation, submits the following in response to the recently announced Personal Data Notification & Protection Act and several related draft legislative proposals. OTA represents over 100 organizations committed to the development and advancement of best practices, meaningful self-regulation, data stewardship and balanced legislation. Last month, OTA released its 2015 Data Protection & Breach Readiness Guide developed through feedback from over 100 security and privacy professionals, and held four town halls around the United States where over 500 attendees provided input concerning the various data breach notification proposals. America’s leadership is being threatened and data breaches are a challenge to national security, the economic prosperity of our nation, and most importantly, to the privacy and financial protection of our citizens. Below is a summary of six key points and provisions which we believe are important considerations for an effective and balanced federal data breach notification law.

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