On December 1st, 2010, the Federal Trade Commission released a preliminary consumer privacy report entitled, “Protecting Consumer Privacy in an Era of Rapid Change: A Proposed Framework for Businesses and Policymakers.”

Among other suggestions, the FTC report came down in favor of the implementation of a “Do Not Track” mechanism, described in the FTC press release as a “a persistent setting on consumers’ browsers – so consumers can choose whether to allow the collection of data regarding their online searching and browsing activities.”

In order to improve its recommendations, the FTC opened up its report to public review and comment. Over the last two months, a wide range of individuals, industry groups, and corporations have shared their comments on the report.

At Reputation.com, we have engaged with government and private sector leaders on the issue of privacy and data management since our inception. In keeping with our tradition of thought-leadership in the privacy sphere, we also submitted comments on the FTC report. To download our report in full, click the following PDF link: “Reboot Online Privacy” Comments to the FTC from Reputation.com. You can also read our report via the Scribd.com embed below.

Here are some of Reputation.com’s key points from the report. For greater context, please also view Reputation.com’s Comments on the Commerce Department’s Green Paper on Privacy.

- When data is collected online, it will inevitably be used online. That is why Reputation.com focuses its recommendations around strong regulations on data collection rather than data usage.

- However, patchwork regulations customized from industry to industry in response to emerging threats will also be ineffective due to the the rapid pace of technological innovation. As such, it is time to “reboot” consumer privacy with the adoption of baseline legislation. It is important that government regulation not give the false perception of protection or protection that is too narrow and inflexible.

- Data freedom and a robust Internet economy do not have to be at odds with practical consumer protection efforts. Indeed, the evolution of a privacy economy led by trusted privacy advocates is an example of how economic innovation and privacy protection go hand-in-hand.

- When considering consumer privacy regulation, regulators must understand that consumers are currently data serfs, working on behalf of only a few data emperors. If other industries — financial, insurance, healthcare —  treated data as many Internet companies do, people would be outraged. Giving consumers control over their data is key in bringing a sense of balance to the data management debate.