In Comments on NTIA Multistakeholder Privacy Process, SIIA Applauds Government’s Role as Convener; Calls for Collaboration Instead of Legislation

Today the Software & Information Industry Association submitted comments to the Department of Commerce regarding the National Telecommunications and Information Administration (NTIA) “Multistakeholder Process to Develop Consumer Data Privacy Codes of Conduct.”

SIIA applauds the NTIA’s process of bringing together relevant parties in order to gather their collective expertise, and reiterated its call for a collaborative, rather than legislative, approach to addressing consumer data privacy. We believe that the proposed multistakeholder process can contribute significantly to the mutual recognition of data privacy regimes, including the European Union’s proposed data protection regulations.

SIIA looks forward to actively participating on behalf of our members and the industry broadly.

In its submission, SIIA says, “As highlighted by the Privacy and Innovation Blueprint, voluntary, enforceable codes of conduct are the appropriate approach for privacy protections because they develop faster and provide more flexibility than legislation or regulation. SIIA also concurs that the Government’s role in this process is primarily as a coordinator, acting as an active convener of the many stakeholders that share the interest of continued development of the digital marketplace.”

“The Federal Trade Commission has substantial authority to take action against actors it thinks has violated its privacy policies and is able to enforce a company’s promise to abide by a code of conduct through its authority to prevent deceptive practices.  As a result, SIIA believes that the multistakeholder process can and should proceed in the absence of new privacy legislation.”

SIIA goes on to make recommendations in several specific areas, and also calls on NTIA to adhere to several key principles while undertaking the multistakeholder process, including: 1) maintaining a commitment to openness and transparency of process and decision-making; 2) ensuring that the Department of Commerce plays an active role as convener; 3) enforcing a structure that has a timeline for deliverables, clear criteria for what counts as consensus and a division that allows progress to be made in sub-groups, and; 4) ensuring a process that is open to all affected parties, but does not preclude the submission of draft documents for review by the group.

For a copy of SIIA’s complete comments to the agency, click here.


David LeDuc is Senior Director, Public Policy at SIIA. He focuses on e-commerce, privacy, cyber security, cloud computing, open standards, e-government and information policy.

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