Privacy Framework

Background

In examining the personal data industry landscape, we have consistently found that many current practices do not sufficiently address valid privacy concerns about the use of consumers’ personal information. Moreover, we would argue that it is difficult to apply traditional privacy frameworks to address this problem. Customary consumer safeguards (e.g. notice and consent) do not effectively scale to match the unique privacy challenges posed by Big Data.

The public record industry in particular must also face an additional challenge: balancing the public interest with the individual right to privacy. Traditional frameworks do not provide direct guidance for striking this balance, and sector-specific regulations have not coalesced at either a federal or state level. As a result, there is currently no uniform privacy standard within the public record industry. This creates consumer distrust and hinders positive technological advancements.
In developing the principles included here, we closely examined ten of the most influential and commonly used privacy and security frameworks, to see how various approaches to privacy have been developed through time and across industries. Some, such as the Fair Information Practice Principles endorsed by the Center for Democracy and Technology, are broadly applicable. Others, such as the Digital Advertising Alliance’s Data Collection Principles, are highly tailored to a specific industry.

Framework Development Process

Next, we examined the privacy practices of companies that deal with significant amounts of personal information, such as Google, Facebook, LinkedIn, Twitter, and BlueKai. The EFF’s annual “Who Has Your Back?” report provided some useful privacy practice summaries, and the user rights initiative Terms of Service; Didn’t Read filled in the remaining gaps with some additional analysis of various online privacy practices.

Ultimately we conclude that a holistic approach to privacy, that addresses all stages of the data lifecycle, is the only sustainable long-term strategy that will create meaningful consumer protections and benefits. Integrating the following principles into our business practices enables us to directly achieve positive-sum outcomes for all stakeholders.

The Principles

These seven principles guide our privacy practices at Inflection: