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USACM Comments on Commerce Department Internet Privacy Report


For Immediate Release

February 2, 2011

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Below is a statement from Stuart Shapiro, Chair of the USACM Security and Privacy Committee, and Principal Information Privacy and Security Engineer at the MITRE Corporation. 

“USACM believes that it is of vital importance for technologists and policymakers to effectively accommodate individual privacy rights and valid government and commercial needs.  This complex task needs to be approached proactively by all stakeholders, since effective data privacy policies and practices can provide benefits to individuals, organizations, and society. 

“While we support the broad adoption of Fair Information Practice Principles (FIPPs), we also advocate additional practices to more comprehensively address this critical issue.  They include a dataflow-based lexicon that defines the specifics of personal information flows, and that distinguishes among the diverse set of industrial and government data purposes. They also include general or sector-specific privacy risk models that include norms and harms, neither of which are fully addressed in FIPPs.  We also advocate greater use of privacy impact assessments (PIAs), which can provide a useful way to disseminate and apply these privacy risk models. 

“There appears to be an emerging understanding that simple opt-in and opt-out choices for consent are inadequate for the vast variety of consumer online data collection and use.  Consent must be more nuanced in effect and more usable in practice.  Achieving these qualities in any Do Not Track implementation will not be simple, and will require enforcement on both the client and server sides of online interactions. 

“USACM does not accept the view that individual privacy must typically be sacrificed to achieve effective implementation of systems, or that cost concerns are a sufficient reason for inadequate privacy protections.  Computing options are available today for meeting many private sector and government  needs that fully embrace our recommendations.  In addition, new technologies are being investigated and developed that can further protect privacy. USACM looks forward to continuing to provide resources and input to policymakers throughout the review of this issue.” 

Read USACM’s public comments.


With nearly 100,000 members, the Association for Computing Machinery (ACM ) is the world’s largest educational and scientific computing society, uniting computing educators, researchers and professionals to inspire dialogue, share resources and address the field’s challenges. The ACM U.S. Public Policy Council (USACM ) serves as the focal point for ACM's interaction with U.S. government organizations, the computing community, and the U.S. public in all matters of U.S. public policy related to information technology. 

For more information contact:
Virginia Gold