SIIA is supportive of the FTC’s effort to provide guidance for the multistakeholder approach to mobile privacy protection being led by the NTIA.
Today’s mobile guidance report from the FTC provides some useful input to that end. However, SIIA continues to strongly disagree with some of the high-level conclusions reached by the Commission. Particularly, SIIA strongly disagrees with the FTC’s conclusion that “[m]ore than other types of technology, mobile devices are typically personal to an individual, almost always on, and with the user.”
While this may be true when applied to smartphones and the model for their use today, SIIA strongly believes that this vision misses the mark for tablets, and it most certainly inaccurately portrays the evolving nature of Internet-based technology and new-age devices. On the contrary, SIIA is confident that the larger trend in technology with products and services offered seamlessly across a wide range of platforms and devices, coupled with the increasing saturation of Internet-powered devices reflects the shift to an environment where devices are less “personal” and less linked to a particular individual than personal computers.
For instance, just several years after the introduction of the tablet computer, and less than a decade after the introduction of the the modern smartphone, it is not uncommon for a household to have a wide range of internet-connected devices, with perhaps the majority of those devices being mobile devices shared by numerous users.
SIIA believes that the FTC’s fundamental misunderstanding about the increasing personalization of devices sets an inappropriate basis on which to build a foundation of privacy practices, either voluntary or mandatory. In order to develop an effective privacy framework for rapidly evolving technology, it is critical that we fully understand how this evolution is taking place, and all the opportunities that this innovation brings.
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. Follow the SIIA public policy team on Twitter at @SIIAPubPolicy.