[Gnso-ppsai-pdp-wg] Consumer Privacy Bill of Rights 2015

Carlton Samuels carlton.samuels at gmail.com
Tue Mar 3 22:00:05 UTC 2015

For those with an interest and apropos our discussion earlier today, the
White House released a discussion draft of the long-awaited consolidated
Consumer Privacy Bill of Rights; see attached.

>From my quick scan, it seems to cover all the expected rights......and
corresponding obligations. But the devil may yet be lurking in the details.

It has a very broad definition of personal data -  “*any data … under the
control of a covered entity, not otherwise generally available to the
public through lawful means, and … linked, or as a practical matter
linkable by the covered entity, to a specific individual, or linked to a
device that is associated with or routinely used by an individual.*”   The
exceptions to this definition are also instructive;  cybersecurity and
anonymised data included.

You may also wish to pay special attention to Sections 403 and 404.  It
makes for a great interpretation of a saying from my part of the world;
giving with the right hand even as you take back with the left.


Carlton A Samuels
Mobile: 876-818-1799
*Strategy, Planning, Governance, Assessment & Turnaround*
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