Drawing on its eleven years of experience facilitating multistakeholder processes, on April 2, 2012, the Centre for Information Policy Leadership at Hunton & Williams LLP filed comments in response to the Department of Commerce’s National Telecommunications and Information Administration’s request for public comments on the multistakeholder process to develop consumer data privacy codes of conduct. The NTIA’s request relates to the topics and processes that will inform the creation of binding codes of conduct as discussed in the Obama Administration’s February release of a framework for a Consumer Privacy Bill of Rights.

In its remarks, the Centre indicated support for the multistakeholder approach, but proposed a process that would allow industry stakeholders the opportunity to engage in frank discussions among themselves, without media coverage or concern that their comments might be recorded. While the Centre’s proposal emphasized that industry should draft codes of best practices, it also highlighted the need for feedback from experts, advocates and regulators, specifically through a public workshop and written comment period. The Centre also urged the multistakeholder working group to prioritize the development of industry best practices for accountability.