ACT filed comments today to offer guidance to the National Telecommunications and Information Administration’s efforts to initiate a multistakeholder process to develop privacy codes of conduct. Initial indications by the agency that it would target apps before addressing industry-wide issues is of great concern to our organization. Targeting technology instead of behavior is the cardinal sin of regulation. The key issue is not apps or the devices that run them, but consumer data. Users are concerned about their personal information and how it is collected, retained, and shared. ACT believes the NTIA should adopt a broad framework that focuses on these key elements. Ultimately, the goal is to ensure that industry practices meet consumer expectation.

The full text of our submission is here.