By Jedidiah Bracy, CIPP/US

As it approaches its 20th year of consumer advocacy, the Privacy Rights Clearinghouse (PRC) this week has unveiled an online tool to make filing a privacy complaint simpler. PRC Director Beth Givens says this new tool will not only help streamline and simplify the complaint process but also will educate consumers and connect them with the appropriate channels for help.

Found on the PRC website, the online complaint tool involves a five-step process, which takes about five minutes to complete. In addition to providing an e-mail address and state in which an incident occurred, users can choose with whom they would like to share their complaint--whether a government agency like the Federal Trade Commission, a lawyer who is “sympathetic” to a given issue, or the media--if anyone at all.

The tool aims to help the consumer determine against whom the privacy complaint should be filed--whether a business, government agency or individual. The complainant can describe the incident and attach documents that support a given complaint. For example, a user could file a complaint against a social network for refusing to delete undesirable photos posted by an individual for malicious reasons. The complaint could include a description of the incident, photos and a request to share the complaint with a government agency.

The interactive tool also features an autofill function that is sourced by the Consumer Action Handbook--published annually by the General Services Administrations’ Federal Citizen Information Center.

A catalyst for the new complaint mechanism stems from a study conducted by researchers at the University of California-Berkeley School of Information in 2009. In the KnowPrivacy report, researchers found that in addition to individuals’ concerns about controlling their data online and the apparent lack of awareness of companies’ data collection practices, users simply did not know to whom they should file a privacy complaint. “Even the act of complaining about privacy,” the report states, “is frustrated by a lack of clarity. Consumers do not know where to complain, in part because privacy policies do not provide clear information about remedies.”

At a PRC-hosted event that same year, consumer advocates discussed emerging trends, including the need for a privacy complaint magnet. Givens says that Chris Hoofnagle, director of the UC-Berkeley Center for Law & Technology's information privacy programs and senior fellow to the Samuelson Law, Technology & Public Policy Clinic, called attention to this need.  

After receiving grant money from the Rose Foundation, the PRC was able to embark on developing the interactive complaint tool.

Givens says it explicitly prevents a user from providing sensitive personal information.

“People tend to give out their PII,” she says. “We want to make sure people do not include that information during the process.” She also says a user can provide a pseudonym instead of their real name.

Givens is pragmatic about potential abuse of the complaint tool, saying malicious intent is certainly possible, but “strategies are in place” to prevent harm.

Once submitted, the user receives a confirmation code and is asked if they would like to register. Registration allows users to track their complaints. The consumer is also given a list of pertinent fact sheets related to the incident. For example, if the complaint involved a social networking site, fact sheets might include ones on social networking privacy, Internet safety for children or employment background checks.

The goal is to get users to share their complaints, which allows the PRC to “raise awareness and work for change.” The PRC form points out that government agencies, lawmakers and the media are often "not interested in investigating a privacy abuse unless they know that it affects many individuals. By sharing, you are not only raising awareness, but you are also increasing the chances that key decision makers and gatekeepers will eventually take action on this issue.”

Givens is optimistic that the new complaint form will increase the overall volume of complaints that the PRC processes and is prepared to add staff.

“The Privacy Rights Clearinghouse complaint center will give consumers an easy-to-use avenue for complaints,” says Hoofnagle, “one that leads to substantive responses, and one that leads to a more precise characterization of consumer privacy interests.”


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