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Notice of Inquiry on Information Privacy and Innovation in the Internet Economy


(Late Submission)
See attached

Please accept the attached PDF as timely filed comments submitted by ARMA INTERNATIONAL in response to the NOTICE OF INQUIRY entitled INFORMATION PRIVACY AND INNOVATION IN THE INTERNET ECONOMY as published at 75 FR 21226 (April 23, 2010). Please direct any questions regarding this transmission or the attached filing to

(Late Submission)
The attached personal comments are submitted for consideration as part of the Department’s comprehensive review of privacy policy and innovation in the Internet economy, pursuant to the Department of Commerce’s April 23, 2010, Notice of Inquiry.

Edward McNicholas, Esq.

(Late Submission)
The Online Trust Alliance (OTA) hereby submits its comments to the Department of Commerce’s Notice of Inquiry, dated April 20, 2010. OTA is encouraged by the dialog regarding the evolving role and importance of privacy protections and the way in which it balances the impact to the vitality of online services and commerce. Balanced legislation and market based incentives are needed to provide a framework for legitimate businesses to follow which neither imposes an unreasonable burden, nor prevents aggressive enforcement towards bad actors.

OTA looks forward to continuing collaboration with the Department of Commerce on this and other initiatives and work streams including cybersecurity, protection of intellectual property and the free flow of information. Working together we can help ensure the vitality of online services and commerce


Craig D. Spiezle
Executive Director

(Late Submission)

In the Matter of

Information Privacy and Innovation Docket No. 100402174-0175-01
in the Internet Economy

COMMENTS OF Deirdre K. Mulligan

(Late Submission)
Attached please find comments from TRUSTe on Information Privacy and Innovation in the Internet Economy in response to Docket No. 100402174-0175-01.

Please let me know should you have any questions.

Best regards,

Elizabeth Frazee


(Late Submission)
Dear Sir or Madam,

Please find my comments in the attachment as an HTML document (MD5 checksum db49eca8f575fff2e96184563b6ccf0d).

Many thanks,
Yours faithfully

Sören Preibusch

(Late Submission)
To Whom It May Concern,

Attached are the comments of the Center for Democracy & Technology in response to the NTIA Internet Policy Taskforce's NOI on Information Privacy and Innovation in the Internet Economy.


Erica Newland

(Late Submission)
Please see attached comments of the Coalition for Online Accountability in response to the NOI published April 23, 2010. Please let me know if there are any questions or problems with the attachment.

Steven J. Metalitz, counsel to COA

(Late Submission)
Please find attached the submission of the Software & Information Industry Association (SIIA) to the above referenced NOI.

Please do not hesitate to contact us if you have difficulty opening the attachment, have any questions, or need additional information.


Mark Bohannon

(Late Submission)
Attached is a PDF including all of the submitted comments. Comments can be navigated using the bookmarks tab.

(Late Submission)
PRISM (Professional Records and Information Services Management) International is a 501(c)(6) trade association headquartered in North Carolina and serving members in more than 60 countries. The members of PRISM International provide paper records management, data protection services, imaging and conversion services and confidential destruction services to multiple clients for profit. Approximately 650 member companies belong to PRISM International. PRISM International also maintains a secretariat office in Brussels.

Since 2008, PRISM International has been actively engaged with members of the European Parliament and European Commission regarding the transposition and implementation of the Data Retention Directive. This directive was put in place as an anti-terrorism measure and was perceived by some telcom companies and European ISPs as an unfunded mandate to retain transactional data beyond the time limit for ordinary business use.

In general terms, the European Union has been more sensitive on issues related to privacy than Americans as evidenced by the European-driven Safe Harbour provisions and recent regulatory action by Germany regarding Google data collection practices. The European Data Retention Directive attempts to strike a balance between the need for individual privacy through limiting retention periods for telcom and ISP transaction data, and law enforcement’s need to act quickly to trace the communication channels of terrorists. While the full effect of the directive’s transposition has not been felt as yet, (the ISP provisions have not yet gone into effect), the need for balancing individual privacy on the Internet does seem to be an issue of growing concern among Americans. (The recent backlash against the change in privacy settings by Facebook is a recent example).

The following is an excerpt from a white paper provided to the European Commission from PRISM International, which articulates some of the European privacy concerns.

“Because the directive establishes limits on the length of time data can be retained, citizens of EU Member States have expressed concerns that there is some type of verification of the destruction of data. These types of concerns seem to be increasing with each incident where retained data are inadvertently released. This includes data from governments. MEP Alvaro expressed this concern very clearly in a September, 2008 speech in Plenary where he said, "The Commission and Council are striving, with an incredible amount of activity, to take action in the field of the economic protection of personal data. When we see what is happening in the United Kingdom, Germany and other Member States, where there are cases of loss or theft of personal data administered by public authorities, we have just as urgent a need for action here. This is ultimately more than ever about citizens’ rights, as they are not able to prevent their government behaving in this way. With enterprises, the citizen is still able to choose a different one in case of doubt.”

“MEP Alvaro’s point regarding a citizen’s choice in case of doubt is key. Even though telcom companies and ISPs use any and all means of verification that they have destroyed data, within the minds of some citizens there is likely to remain some question as to whether this has been done unless the data moves beyond the control of the organization and is housed with a third party. In this scenario it is possible to imagine a much higher threshold of verification. Moreover, access to this data can also be made more secure by encrypting the data prior to sending it to a third party for storage. Data outsourced in this way is stored by a company who does not have the means to access it (an encryption key). The data owner no longer has physical possession of the data and thus has no without a means of preserving the data past its point of expiration (without the direct intervention of law enforcement due to an active investigation or legal hold). This type of arrangement works very similarly to a separation of duties control in accounting. There must be cooperation between the vendor and the client in order to act. Aside from the added benefits of data security in this arrangement, we believe the additional layer of verification and transparency of data will probably be of the most benefit to telcom companies and the public.”

Thank you for the opportunity to submit these comments.
James E. Booth
Executive Director
Jim Booth
Executive Director
PRISM International
1418 Aversboro Rd. Suite 201
Garner NC 27529 USA
Voice: +1-919-771-0657
Fax: +1-919-771-0457

(Late Submission)
Dear NTIA:

Please find the attached comments of Data Foundry, Inc. for the Information Privacy and Innovation in the Internet Economy Notice of Inquiry (Docket No.

These comments were originally timely filed on June 14th, but, due to an error in the "to" field of the email submission, the message was not delivered. I just received a delivery failure notice from my email provider (which you can see below), so I am now resubmitting these comments. I hope that our comments can still receive the same attention and consideration had this error not occurred.


Matthew A. Henry

See attachment.
Martha R. Johnston
Director of Government Relations

I submit the attached comments on my own behalf. Thank you.

(Late Submission)
To Whom It May Concern:

Please find attached TechAmerica’s comments submitted in reply to the Department of Commerce’s Internet Policy Task Force’s NOI entitled “Information Privacy and Innovation in the Internet Economy.”

Thank you.

Christopher E. Wilson
Director and Counsel, E-Commerce & Telecommunications

(Late Submission)
Dear Sirs,

please find attached comment from W3C Team to the Notice of Inquiry:
Information Privacy and Innovation in the Internet Economy.

Yours sincerly

Rigo Wenning
W3C Privacy Activity Lead

(Late Submission)
To Whom it May Concern:

Please see the attached comments of Google for filing in Docket No. 100402174-0175-01.


Will DeVries

Will DeVries | Policy Counsel | Google, Inc. | 202.346.1227 |

(Late Submission)
I am please to submit the attached submission of The Future of Privacy Forum in response to the Department's privacy NOI.

Thank you,

Christopher Wolf

(Late Submission)
Attached please find the comments of Datran Media regarding privacy and innovation in the internet economy.

Thank you.

(Late Submission)
Attached is the CDIA's comments regarding the NTIA/ITA/NIST notice published in the Federal Register, Vol. 75, No. 78/Friday, April 23, 2010 entitled "Information Privacy and Innovation in the Internet Economy.