In Reply Comments to FCC, CDD Explains Why Consumers Require Privacy Protection from Broadband Network Providers

We believe that the absence of any FCC rulemaking to protect the privacy of broadband customers would significantly add to the already prevalent sense of confusion and sense of loss of control among broadband internet customers under the existing FTC regime. Instead, the proposed rules will give ISP customers much needed control over their data and are much more likely to increase consumer confidence. 

Second, we would like to emphasize that current BIAS provider data practices already undermine the privacy of their customers and that they are in the process of further building out their powerful data management capabilities. Due to these practices and their significant position in the data eco system, BIAS providers are a growing and significant marketplace force in digital advertising.  Contrary to companies’ and trade associations’ claims, we see no evidence that giving BIAS providers’ customers effective privacy choices will limit the online advertising industry to flourish.  The American public wants to see its privacy protected and needs the safeguards proposed by the Commission.  Nothing less will limit the expansion of an unprecedented intrusion of BIAS providers into the most private aspects of American consumers’ lives. The Commissions’ proposed rules are needed to protect individual autonomy and the fundamental right to privacy and self-determination.

see attached for the complete Reply Comment

Also attached is joint filing showing how the so-called "Multistakeholder" Process on privacy, organized by the Department of Commerce, has repreatedly failed to protect the public.