Last week, the U.S. Chamber of Commerce and the U.S. Chamber of Commerce’s Institute for Legal Reform (“ILR”) submitted comments to the Uniform Law Commission (“ULC”) in regards to the Draft Act concerning the collection and use of personally identifiable data. As readers of CPW will recall, the ULC has a Personal Data Act Protection Committee, tasked with drafting a model law addressing the collection and use of personally identifiable data. This includes provisions governing the sharing, storage, security, and control of the personal data of others.
The Chamber agrees with the ULC that uniformity should be the ultimate goal with regard to privacy policy and for this reason supports adoption of a national privacy law to provide privacy protections to all Americans equally. As discussed in greater detail in the Chamber’s comments, the Chamber also opined that any model privacy bill (in the absence of national legislation) should: (1) promote “uniformity and certainty,” (2) “grant individuals clearly defined privacy rights,” and (3) promote certainty through enforcement by the state attorneys general rather than private rights of action.
To see the Chamber’s detailed recommendations regarding language in the Draft Act, check them out here. As CPW has previously covered, several states are in the process of considering various privacy bills that have the potential to significantly impact this rapidly developing area of the law. For more, stay tuned.