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	<title>Comments for SIIA Digital Discourse</title>
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	<lastBuildDate>Thu, 26 Apr 2012 21:48:20 +0000</lastBuildDate>
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		<title>Comment on Mobile Payments Get Currency by Mark MacCarthy</title>
		<link>http://www.siia.net/blog/index.php/2012/04/mobile-payments-get-currency/comment-page-1/#comment-2399</link>
		<dc:creator>Mark MacCarthy</dc:creator>
		<pubDate>Thu, 26 Apr 2012 21:48:20 +0000</pubDate>
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		<description>I want to focus on the area of agreement with Harley.  His work highlights the possibility that actors in the emerging mobile payments market could share more information than was shared in traditional payments card transactions. He’s right, and he’s gotten the attention of policymakers on this point.  Jessica Rich, head of the FTC’s Office of Financial Practices, summed up the situation at the end of today’s mobile payments workshop by saying that players in the mobile payments space “could collect rich data sets from consumers.” 

But market participants know this exchange of information can only be done successfully with consumer permission.  They have built privacy protections and choice mechanisms into their systems from the beginning.  So these possible privacy risks for consumers are not present in the market because market players have controlled them.  As Harley says, “companies have built in user controls to mitigate the risks of exposing consumer information.”  So consumers should feel confident that they can use the new mobile payment technologies, get all the benefits of extra convenience, innovation and security AND control information sharing for marketing purposes arising from this context of mobile payments.   The job now for the industry, for privacy advocates and for policymakers is to keep the market moving in this positive direction.</description>
		<content:encoded><![CDATA[<p>I want to focus on the area of agreement with Harley.  His work highlights the possibility that actors in the emerging mobile payments market could share more information than was shared in traditional payments card transactions. He’s right, and he’s gotten the attention of policymakers on this point.  Jessica Rich, head of the FTC’s Office of Financial Practices, summed up the situation at the end of today’s mobile payments workshop by saying that players in the mobile payments space “could collect rich data sets from consumers.” </p>
<p>But market participants know this exchange of information can only be done successfully with consumer permission.  They have built privacy protections and choice mechanisms into their systems from the beginning.  So these possible privacy risks for consumers are not present in the market because market players have controlled them.  As Harley says, “companies have built in user controls to mitigate the risks of exposing consumer information.”  So consumers should feel confident that they can use the new mobile payment technologies, get all the benefits of extra convenience, innovation and security AND control information sharing for marketing purposes arising from this context of mobile payments.   The job now for the industry, for privacy advocates and for policymakers is to keep the market moving in this positive direction.</p>
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		<title>Comment on Mobile Payments Get Currency by Harley Geiger</title>
		<link>http://www.siia.net/blog/index.php/2012/04/mobile-payments-get-currency/comment-page-1/#comment-2380</link>
		<dc:creator>Harley Geiger</dc:creator>
		<pubDate>Wed, 25 Apr 2012 19:58:38 +0000</pubDate>
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		<description>Hello. I am the author of the CDT blog post on mobile payments &amp; privacy, to which your post links. The privacy risks I discuss are not &quot;speculative&quot; at all, and your post supplies the proof: companies have built in user controls to mitigate the risks of exposing consumer information. I wrote about the privacy risks of mobile payment services that do not have strong user controls. Clearly some of the companies have built in user controls because they foresee the very same risks I describe. This is an important issue for the industry to address – surveys consistently show consumers strongly oppose the disclosure of personal information via mobile payments. 

It&#039;s great that some companies have enabled consumers to withhold personal contact information without affirmative consent. In fact, I specifically call upon companies to do so at the end of my own post! These and other user controls will help maintain consumer trust and avoid unnecessary regulation – but the controls must be meaningful and should apply to all the companies in the mobile payment ecosystem. The mobile payments marketplace is still nascent and we will see many more services over time, and likely not all the companies that enter this market will be scrupulous with consumer data. Remember also that the privacy issues relate not just to mobile payment service providers, but also third party apps connected to the core service, like a budget or coupon app linked to the mobile wallet. 

Thanks for linking to my blog post and for discussing this issue.

Sincerely,


Harley Geiger
Policy Counsel
Center for Democracy &amp; Technology</description>
		<content:encoded><![CDATA[<p>Hello. I am the author of the CDT blog post on mobile payments &amp; privacy, to which your post links. The privacy risks I discuss are not &#8220;speculative&#8221; at all, and your post supplies the proof: companies have built in user controls to mitigate the risks of exposing consumer information. I wrote about the privacy risks of mobile payment services that do not have strong user controls. Clearly some of the companies have built in user controls because they foresee the very same risks I describe. This is an important issue for the industry to address – surveys consistently show consumers strongly oppose the disclosure of personal information via mobile payments. </p>
<p>It&#8217;s great that some companies have enabled consumers to withhold personal contact information without affirmative consent. In fact, I specifically call upon companies to do so at the end of my own post! These and other user controls will help maintain consumer trust and avoid unnecessary regulation – but the controls must be meaningful and should apply to all the companies in the mobile payment ecosystem. The mobile payments marketplace is still nascent and we will see many more services over time, and likely not all the companies that enter this market will be scrupulous with consumer data. Remember also that the privacy issues relate not just to mobile payment service providers, but also third party apps connected to the core service, like a budget or coupon app linked to the mobile wallet. </p>
<p>Thanks for linking to my blog post and for discussing this issue.</p>
<p>Sincerely,</p>
<p>Harley Geiger<br />
Policy Counsel<br />
Center for Democracy &amp; Technology</p>
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