Submission Number: 00060Â
Received:Â 12/30/2011 5:10:29 PM
Commenter: Michael Schiffer
Organization:Â
State:Â Illinois
Agency: Federal Trade Commission
Initiative:Â Proposed Consent Agreement In the Matter of Facebook, Inc., FTC File No. 0923184
Attachments: No Attachments
Submission Text
This agreement fails to go far enough, particularly given Facebook's persistent "easier to get forgiveness than permission" history. At a bare minimum, users need to be able to maintain knowledge of and control over the information they provide to Facebook, including a right of deletion (with deletion to be confirmable, and any failure to comply subject to civil and criminal penalities, a right to know what information has been provided about them and to whom.
Likewise, any privacy policy changes should be required to have a prominent announcement at least thirty days before implementation.
Most importantly, Facebook should be subject to random, unannounced audits by third parties, rather than having them be on a specific predetermined schedule. These audits should limited in number to not be unduly burdensome, but Facebook should not be in a position where it can arrange to only appear to be in compliance when a known deadline is approaching.