They suggest the Fair Credit Reporting Act (FCRA) as a model for this.
FORBES: Brief Takeaways -- and a Pretty Diagram -- from the FTC's Online Privacy Recommendations
The fall 2003 amendments to the FCRA include a provision that broadens the law's preemptive scope--the bankers say this means the FCRA now preempts SB1.
Because of the FCRA, Social Intelligence has to make sure its clients inform job applicants if they took adverse action based on something found on the Internet.
England Jr. of the U.S. District Court in Sacramento ruled that the FCRA, whose overriding purpose is to regulate the use and dissemination of consumer reports, does not preempt SB1.
But industry groups apparently had other plans of attack to invalidate the affiliate sharing provisions of SB1: First, lobbying Congress to amend the FCRA, and second, suing in federal court.
The degree of improvement varies from agency to agency and program to program, and we believe the changes required by the FCRA have been positive for the Federal Budget process.
On appeal, the industry groups argue that the district court incorrectly relied on the Gramm-Leach-Bliley Act, and that the FCRA, and 2003 amendments to it, expressly preempt SB1's affiliate sharing requirements.
Prior to the FY 1997 Budget, the subsidy estimates for these programs were based on samples of loan data prepared shortly after the enactment of the FCRA. Administrator Alvarez' statement details the major undertaking completed by SBA in late 1995 to compile and analyze the available historical data for the 7(a) and 504 programs.
One way is to require that entities that deny benefits to consumers based upon information obtained from information brokers provide notice to the affected consumer, similar to an adverse action notice under the FCRA. This would allow the consumer to contact the information broker and access and potentially correct the data upon which the denial was based.
FORBES: Brief Takeaways -- and a Pretty Diagram -- from the FTC's Online Privacy Recommendations
应用推荐