The World Privacy Forum offers comments on the proposed consent order, In the Matter of Ceridian Corporation, FTC File No. 102 3160. The World Privacy Forum is a non-profit, nonpartisan public interest research group that focuses on consumer education as well as analysis and research of privacy issues, including issues relating to health care privacy, technology, and online/offline data privacy. More information on our work may be found at http://www.worldprivacyforum.org.
We have nothing to say in defense of the actions or statements of Ceridian. Our comments focus on the choices made by the Commission in pursuing this matter, in setting out the facts of the case, and in selecting the basis for this action. We want to be clear that we support the FTC’s many actions in support of privacy, and we appreciate the Commission’s efforts on behalf of consumers. However, we are seeing the outlines of some consistent patterns in the Commission’s enforcement efforts, and we have some suggestions and comments regarding potential improvements in these patterns. Our comments below discuss these issues in more detail.
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