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On October 21, 2022, the Cyberlaw Clinic submitted a comment in response to a request from the Federal Trade Commission for feedback regarding an Advance Notice of Proposed Rulemaking related to commercial surveillance and data privacy. The comment was submitted on behalf of the Berkman Klein Center and its projects and associates, including the Data Nutrition Project, the Lumen database, the Risk Assessment Tool Database project, and the Youth and Media project.

The comment provides actionable recommendations that would represent meaningful incremental steps toward an eventual goal of end-to-end data transparency from data collectors and processors. These include tailored transparency mechanisms, flexible disclosure requirements, and protections for vulnerable populations online.


Alice Hu, Ali Jenkins, and Samiksha Ramesh (all HLS JD ‘24) — all students in the Cyberlaw Clinic this fall semester, 2022 — drafted the comment, working with Jessica Fjeld and Chris Bavitz on the Clinic team. For Berkman Klein, Sue Hendrickson, Kasia Chmielinski, Sandra Cortesi, Adam Holland, Adam Nagy, Sarah Newman, and Shreya Tewari contributed to the comment.

Read more on the Cyberlaw Clinic blog or download the full comment.

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