The Network Advertising Initiative wants better notice and choice mechanisms...

of contractual mechanisms that protect against linkage,” NAI said. The report’s reasonably-linked standard could bring about unnecessary disclosure that “highlights the potential utility that self-regulatory mechanisms could play in fostering consumer awareness of data collection.” The report’s data retention principle reflects how the self-regulatory approach “can further the goal of improved substantive privacy protections,” NAI said. “Self-regulatory frameworks can not only address how retention information can be made more transparent to consumers, but also establish best practices that normalize retention periods for particular classes of data.” The final FTC report should include “an identification and brief discussion of existing laws and regulations that apply to certain commercial business sectors,” like the healthcare industry, said America’s Health Insurance Plans. The healthcare sector is governed by a complex framework of statutory and legal requirements, AHIP said. The existing requirements “are very similar to the elements advanced in the report.” “Including financial services in the scope of the preliminary report may not only call into question the paper’s role to the extent it is inconsistent with the current governing regulatory requirements, but it may be disruptive to financial institutions’ privacy framework and have unintended consequences,” the American Insurance Association said.