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Comments to FTC on Commercial Surveillance and Data Security

In August, the Federal Trade Commission released an advance notice of proposed rulemaking seeking comment on avenues to regulate commercial surveillance and data security practices that harm consumers. Policy Integrity submitted comments recommending that the FTC regulate “immortal accounts,” a practice by which entities make it difficult or impossible to delete a consumer account in order to retain and profit from the user’s data and continue charging subscriptions. Our comments were based on a report that we recently published establishing the Commission’s authority to regulate this pervasive practice.