As a people feel that the policy issues of privacy. The commission has been in the spotlight with major cases in the Facebook Cambridge analytical and that youtube settlement and a series of hearings on competition and Consumer Protection in the 21st century with with a lot of that focus with data and privacy. We are fortunate to have with us today to commissioners, rebecca slaughter and christine wilson, both of whom have long background in Public Policy and becca slaughter is on the hill and wilson previously as chief of staff at the commission and both experienced in private law practice and other capacities so i want to jump right into it. Lets begin, if we could with an overview. You started in may of last year, christine in september so you both are about a year on and have experience in cases and hearings. How do you see the privacy we have today . What do you see as the key issues as we move forward . You are the senior commissioner on the panel [laughter] , 18 months of experience now. Thank you for having us. Its nice to be here and nice to be here with christine. This is an issue we both care about and are excited to talk about this together. What are the key issues . Honestly this is an issue which ive given a lot of thought from the perspective of enforcement which is different from the policy perspective that i had and once i had for so long on the hill. A few observations that are key in my mind now. The first is that i think that when we just use the term ivc we may be unintentionally capping ourselves to to narrow a universe of thought about the data issues we are facing because privacy generally refers to sharing of information the people would rather not have shared and there are real harms that paul from that in real sense of values that we need to protect. We need to separate those harms from the harms that flow from the use of that data to turn around for people or target manipulative information or harmful information and my first observation is that ive been trying to think about data abuses rather the narrow frame of data privacy because i dont want us to get to cabin into a universe that prohibits thinking about the full panoply of issues that we are encountering. The second big observation that i would share is i am over noticing consent in this universe. Noticing consent the remark that forms a lot of sec enforcement action in makes sense. Tell people what youre doing with fair data and you keep your promises and we can enforce where you buy or you dont. That sounds reasonable but for noticing consent to be meaningful both notice and consent have to be meaningful and in the space of data i dont think either are particularly. If you take notice first of all, weve all seen the statistics about how long it would take normal people or even very well educated people to read the privacy policies they encounter in a year or months and people dont do it and even if you try to do it i tried to do it and i cant understand what is being done with my data in a lot of cases. I have the best tools at my disposal of basically anyone to do that analysis. I dont think the notice is particularly meaningful and consent is not particularly meaningful because these options are take it or leave it and even if you win the policies you cant turn around and say combined with paragraphs one through eight but please make these edits in nine and then i will click consent. You just have to say yes and often have to say yes to access the Service Necessary for your participation in society. I think we need to reframe the guideposts away from the concept of noticing consent and think more about the expectation. What do consumers expect will be done with their data and what is reasonable from that framework and last point i make and then ill turn it over to christine is that i think we need to be particularly sensitive to how these problems of databases and how the challenges of noticing consent fall disproportionately on vulnerable populations and that is important from a policymaking prioritization standpoint and how we think about enforcement efforts. I think with those observations i will defer to christine. Kim, thank you for having us. Its great to be here and the folks here today will see that we agree on almost everything in this space so. Not to on every issue. My views on privacy and privacy legislation has changed over time and as you mentioned i had the honor of serving [inaudible] when he was chairman of the federal commission into the other one, 2002 and at the beginning of that decade we were grappling with how to deal with privacy issues and is a significant topic of discussion and we brought early cases like eli lilly and the mega soft where its representations were made or data processes resulted in up sharing data in ways consumers would not expect in those were good cases for the ftc to bring and we also brought we created the do not call registry and given the experience we have with robo calls today we realize technology has outpaced the sales rules and in the same way there developers that have outpaced some of the thinking that we did in the early days about how it would be brought to bear. Frankly, we found the authority in this area so i am in favor of regulation and i had to grapple over the last several months with eventually embracing the need for federal privacy legislation and theres a great paper by feel better who explored all the different ways he could address harms and abuses and working through his rubric helped me get comfortable with federal privacy legislation in syria and ultimately as mrs. Need flexibility and certainty in the vast majority want to follow the law but right now theres a lot of gray areas and how to do that and we can all agree on abject principles and how to deal with Consumer Privacy and Data Security and accountability in his risk managements but doing that in an informed way is a difficult without bright line rules and congress and so i think particularly with potentially dcpa coming online and [inaudible] online businesses the that flexibility and i think consumers need more information and significant opacity with respect to with respect to consumer data so i think the average consumer does not understand all of the different Data Collected and what is done with the data once it is collected which shares how it is monetized and how it is transferred to third parties with or without safeguards for the protection of that information and there are significant information and imagery and i would love to see legislation that helps boost that transparency. I believe the consumers can make informed decisions about which services we participate in and avail themselves but without that full information about whats happening those decisions will not be informed and then i think we need privacy education because there are caps that have emerged and evolution and in technology so that that bit that i wear collects health data but is not covered and there are many example like that. I think it has been a long process for me in the year ive been at the commission and the last conversations with becca and my other colleagues that been incredibly patient with me as i work through these issues but im now firmly on the side of meeting federal privacy legislation. Let me explore more on the context and you talked about some additional forms of transparency to increase Consumer Choice and is that enough or do you think there is more needed to address businesses that handle the data beyond consumer. Absolutely. Becca was one of the first people i heard say it in this way but basically it is impossible for consumers to make the decisions that they need to make and so some owners need to see beyond the businesses with a kind ability and with applied Risk Assessments and that sort of thing. I dont think transparency is the beginning and the end of federal privacy legislation and i agree with becca that notice and choice if at all has a useful limited application. So, in that lane when idea the keeps coming up is data ownership and the Senate BankingCommittee Last week had a hearing on that subject and is that simply another form of notice and choice with money thrown into the bargain . I will say not an expert and have not studied policy disposals in the delta my initial reaction is to have anxiety about the idea that if we pay people for their data can solve the problems that we are seeing in privacy and databases. For a month of the reasons data is valuable in aggregate and when many people feel data is collective for many sources and aggregated which means the marginal value of each piece of data is very small so the amount that an individual consumer might realize the monetary value they might realize by being paid for their data actually has a small and were talking about universal people are giving up data without being paid so went a consequence of this likely be that already large countries with more money pay people more to aggregate more data which raises questions serious questions in the competition space as well as in the times he is Consumer Protection space and im not sure what problem it solves because again, forgetting to the point where you for thinking through the lens that data is used in the problematic ways, not just collected in problematic ways facilitating collection by pain people may even exacerbate the use of problems rather than solving them. I have a slightly different in conversations that had people in doj over the last several months and he and i have talked about whether or not that concept of data ownership helps us get to the insert we want so for the good of our target who owns the list of items i purchased and for how much . I need those for my budgeting purposes or inventory or government accounting purposes in the Merchant Bank easy information and who owns that data and so im not sure that talking about data ownership gets us to the answers that we are looking for. You mentioned some of the discussions weve had among commissioners and with others and let me ask you both questions that your colleague knows. This has been raised in other forums and what is the harm that we are trying to prevent . Commissioner wilson. I think its a great question and has a way of focusing the mind and what are the problems we are trying to solve in we dont want to rush and create a vacuum of framework without specifically about the harms that we are attending to address and the ftc already has a vast set of president regarding harms that we view as worthy of avoiding so physical injury and you may want to talk about [inaudible] because you made the announcement there but last year we made the comment about software and its for. Because of privacy jurisdiction, financial, reputational inventory and so we have a case in which computer rental companies actually installed cameras that could be remotely activated and those were in bedrooms. Obviously, the harms that we are seeking to address not limited to potential harms but theres a vast array of harms in the ftc cases provide a wonderful list and overview of the harms it leaves. I think i agree with all of that but i still would have done it. It was our First Software app and you could buy an app and install it on someone elses phone and it came with instructions how to generate the fronts of the present would not be able to know that they were being tracked. This is its not just creepy but lethal in circumstances. Those are incredibly important but it is also important to me and not be the closed universe of harm and so lets think about children, for example. There was a study that came out recently that talked about increase, to medic increase, in teen suicide rates in the u. S. Theres editorial case in the uk of a young woman who took her life at 14 after being the target of online bullying but material that was pushed to her that talked about how to commit suicide with that is indescribably scary and damaging. Thats not a privacy violation in the same way we might have traditionally thought about it but its a real harm from data use, data targeting and i think about about terrorist recruitments or recruitment for hate groups and i think about the targeting of manipulative information to voters and two children and these are all material harms that are important to me in this debate is that we not fall into the trap of thinking we need to be able to quantify her in order to find it quantifiable. Its easy to quantify but need to financial quantify financial harm. Lots of harms are not quantifiable and are still very real. One thing i think that we as an agency need to do and i Hope Congress will do is provide helpful guidance about the harms we think are important but not limit that because i also think there are things we cant anticipate today that will emerge as problems continue to be problems and we need to make sure have the facility to address a merging problems and not just the ones we are aware of now. In terms of harms that are not technically evident but that concern us i am concerned about the impact the Fourth Amendment of essentially developing this sense that nothing is private anymore and in fourth minute law the question is was there a reasonable expectation of privacy that was violated and if in the commercial arena people have the sense that nothing is private anymore how does that impact for the moment jurisprudence when a court or judge making the decision with respect to societal norm was there a reason an expedition of privacy and you have the commercial arena and there is none that has an impact and i am concerned about the erosion from the Fourth Amendment and its not something within the just actions but i think something that we as a society should think about with privacy legislation providing rules about data use and Privacy Protection and expectation and help us reframe the discussion and tell us what is in and what is out of bounds and hopefully provide more guidance to the courts on Fourth Amendment issues. I think we deal with that to some extent by recognizing, as you said, that transactions you have certain interests and your grocery list but so do other people and the question how do we balance those interests . I think that gets us to what may have been a point of departure between you two in the facebook settlement, maybe not so much the point of departure on substance things as such as ftc authority but becca slaughter, you dissented because he wanted to see what you called meaningful limits of what facebook collects, uses and shares. Among other things, yes. But that is always left out on me. Can you flesh that out a little bit . I will go back to the expectation principal that i started with. I think that for the framework for what Data Companies can collect about people starts with what people can recently expect to share. If i is a mapping app i reasonably expect that company to use my location and if i use the flashlight app i do not expect that comedy will need my permission because it does not. I think the first that of limitations should be is the information you are collecting reasonable and necessary to provide the service you are offering. Second, are you using the data in a way that is elected to the service you are offering or are you then going beyond what you are providing to use the data for other information and in the case of facebook, my concern involves the data facebook collects by people beyond what they expect including from third parties and across behavior and across the web not just on the facebook platform and from users who dont anticipate they have any relationship with that company and therefore are sharing information with them. I think these are things that are important but instead of making our framework noticed and choice framework is reasonable expectations of what it has collected and will make more sense in line with not putting with consumers anticipation of how their data will be used and not losing the entire return on them to make they dont have the information or the ability often to meaningfully meet. I do want to say in terms of the disagreement about the facebook outcome i will let christine speak for herself but its fundamentally at the point that i was making was that getting things in settlement negotiations is hard and there may be cases where there things i love to stay in settlement that make it but i supported because the best use of agency resources. In this particular case because of that magnitude of the case and its impact on the markets and the signal it would send and the scope of the companys reit thought was important to fight the court if necessary for the outcome we thought was important at the end of the day but i will also be the first to organize is not maneuver guaranteed to achieve those outcomes at the end of the day. But he thought transparency they came with litigation and finding liability at the end of litigation would be more effective in helping to change the behavior that we uncovered. With respect i dont disagree about seeking how it would be desirable to impose the collection and sharing of information and there was a specific question about whether the ftc within its Current Authority has the ability to do that. We are asking congress to provide those guidelines and to legislate accordingly i did not feel that it was appropriate to legislate for an entire industry through the settlement. So, we had lots of conversations and very helpful to find the same conversations about facebook and frankly, it it was a struggle for me to decide whether to vote in favor of the settlement or to pursue education. I am synthetic to litigation and the transparency that would bring. Ultimately i would convince that consumers need assistance today and the relief we got was real and meaningful and Mark Zuckerberg now has to essentially enter in representations every quarter and he and his company are abiding by the constraints and allegations of the order in early reports indicate that the focusing of the mind is what we saw when we included that requirement in the order is taking place and having a desired effect. Facebook has made tens of thousands of backs in early reports indicate there many other changes taking place behind the scenes and i look forward to being able to talk about those appropriate time and the early reports indicate that the monetary relief there is real change occurring because of this order and that is ultimately what let me to vote in favor of a settlement as opposed to mitigation even though i agree that the benefits of medication my concern is the long and drawn out process that may or may not grant the relief in the end that we could extract here today in the immediate for facebook users. This is what you talked about earlier that youre pumping up the limits of your authority a and. I will say its important and true income that the limits of our authority if we dont litigate in some cases we dont know what they are. It is important for us not to impose on ourselves limits that dont exist in the law and in areas where we have limited litigation experience with this true on order enforcement and Civil Penalties and through and i think its difficult to obsess and we have to apply our best judgment and think about what we in good faith believed to be the limits of our authority but im not convinced those limits exist in the law and i dont think we know that the case until we go to court and if we go to court and find those limits it helps us in making our case to congress about the limitations not the law. Basically my answer is i think we can do both and talk to congress and explain where we see concerns today and push the envelope where its appropriate and interest of consumers at the same time. But talk about that here. What do you see as the constraint today in order to do the job that you talked about being needed in privacy and lets call it Data Protection or information privacy. What do you see as of the constraint today and what is the authority that you need . I will start with where christine started talking about the comfort she has developed with rule making authority. I am substantially more comfort than she does and this is an area where it important for the reasons that christine talked about i find it for straining to hear businesses complain they dont know what is expected but also the same businesses complaint they dont want the ftc making roles telling them what is affected on them. I do think in the area of Data Protection more and more of those are saying it would be coupled to have clear rules of the road spot out in a participatory notice and comment will making process that lets us know what we need to do and how we need to do it so thats the first thing and related to remaking authorities we do not as a general matter of the ftc had the authority to seek monetary relief for first instance violation so we can get disgorgement sometimes or we can get redress for consumers although that authority is also under attack but in the case of privacy that is hard to measure what is an appropriate amount and hard to measure consumer harm and tailor a number to that inner to seek redress in it would be much more effective, i think, from a deterrent perspective to be able to have civil penalty of 31st instance violation. We have that as a general matter because its connected to a rule and the reason you get a civil penalty was because they were already under order for violating the ftc act and i dont think thats in the best interest of society to stop someone unrest once before we can create a financial deterrent penalty. The fact we see case after case after case of privacy and data abuse violations tells me we do not have a broad enough deterrent with the authority that we have. I agree with becca on the need for Civil Penalty Authority and i think that it would be useful deterrent in this area and i think we disagree on the breath of the rulemaking authorities that should be granted to the federal trade commission and popup provides a useful analogy here and we had talked previously about rules for Congress Versus rules for the ftc and i think its up to congress to sketch out the rights the consumers have and the allegation that the businesses should be subject to and there are a lot of models out there that had been used symbol and another of the vance frameworks and im not sure if the difficult part is to instill those into a essentially daily practice of business. How to be taken ability and Risk Assessment and transparency and creates essentially understandable on occasions for businesses that they can abide by and for the ftc to fill in with narrow epa will making so Congress Said we believe its important for children under the age of 13 to have their parents verifiable parental consent before websites collect their information and then the ftc came along and did a narrow rulemaking that said here is how that is verifiable parental consent could be obtained and given and i think thats a nice balance between the role for congress and the role for the ftc in terms of other authority i think the federal trade commission should receive jurisdiction over common carriers and nonprofits. For example, school the hospitals are cutting Sensitive Information and i think those should be subject to ftc Privacy Authority acid commercial businesses. I love to see a rollback on nonprofit exemption and i think as congress is creating the bill it would be wonderful if they take into account the need to preserve incentives for competition and innovation privacy is important and so is competition and so if there are ways that legislation can be crafted that will create the incentives to continue innovating, American Innovation is animating think so how do we foster that while providing productions at the same time for consumers privacy and then couple areas of this agreement that we should have federal preemption and i think consumers and businesses need to know what the right nominations are across state lines in the internet, let alone National Boundaries and so i would support federal preemption and the private right of action with being currently difficult. I think we dont need more to legislation the court but to provide illnesses with guidance about what is and is not appropriate. One of the challenges in the ivy arena particularly in using the Unfairness Authority has been the consumer harm standard and that goes to the question of what the harms are and so, thinking in terms of what legislation might do if congress spelled out some boundaries on the election and you have i proposed a reasonably articulable basis for collecting the data boundaries on the use and boundaries on the sharing and then violation of these is a violation of section five. Does that provide you with enough authority . Absolutely. That is the hope and expectation at least on my part, that congress will provide more clarity about the rights and indications that consumers businesses have. Absolutely. To the extent of the question would be a problem if ftc had to identify particular harms in any enforcement action and its a problem to have to do that with particularity because a lot of the harm that can flow from data abuses is not immediately identifiable and not clear today so take Identity Theft as an example and if my data is stolen today i dont know whether it will be used to steal my identity or open a line of credit in my name in three years. I know it could be. That is a real harm can be used in various other ways but meaning to prove that length is the burden government cant meet and that it would be counterproductive to set up a Regulatory Regime that is intended to protect consumers but is functionally unenforceable by the federal government. I will piggyback off of what christine said. Shes right that we dont entirely agree about pms and in private right of action and i think on the latter. 1 thing i would say is that i have a lot of insight he about posting access to courtrooms for real people in every circumstance but particularly where the ftc has been so systematically underfunded and state attorney general are so systematically underfunded that unless you pair Enforcement Authority with her manic like astronomical increases in resources there is no way you will capture the universal problem and so making sure that enforcement is possible not just in the context of what are the standards but who can do it and who has the resources to do it is important to me. Thats the question we got to deal with the oversight hearing is with me supports giving the authorities to enforce federal privacy legislation and i agree it would be helpful but i also hope we get more resources. On the resources. Youre both done comparisons the Data Protection authorities overseas which orders of magnitude greater numbers to bring to the problem in one of the proposals in a couple of bills of congress is to create a new euro. Ap of Data Protection and which would allow you to combine some of the Technical Expertise of the technology across, both the privacy and protection issues in the competition issues. Is that something that makes sense or should it be parceled in the existing markets . I think we need more technologists, generally. We put an economist on every single casey bring, competition or Consumer Protection. I have seen finishing few cases in my short tenure that would have benefited from the eyes of a technologist. Organizationally how you do it i think theres a lot of good options. One thing i will say is i do think that the ftc is the right place for new authority to be allocated rather than having an dpa. Exactly for the reason he pointed to. One of my concerns about independent dpas they facilitate protection they dont have the Competition Authority or the competition lens and i think it would be through the broader societal deficits for us to not be able to apply that length and that thinking to the kinds of issues that we are seen in the Digital Space because a lot of them sound and competition and Consumer Protection at the same time in one area the ftc is working on improving is having a little more cross pollination between the two traditionally silos and where we have cases that indicate both areas. I know christine and i asked questions about how the staff on the other side see these questions and that is important to have that land to make sure that we are thinking through some of the innovation issues that are implicated in these questions. I think a lot of it and up being all the money questions in competition and in privacy where the dollar is flowing in my early flowing there and how are they being used and we can apply that analysis from both Consumer Protection and a competition simply. I would echo essentially all of what that got set. In the first instance it would be it would still serve the megan taxpayer and enforcement to create a Different Agency to enforce ibc laws and i think the federal trade commission has taken incredibly long time and is moved up the learning curve in terms of incredible sophistication with enforcement of the issues and listening to all the stakeholders about the interplay of the tensions in the interests and stake and how to balance them and how the workshops and roundtables that have issued many reports that are very insightful and hopeful as we seek to enforce in a very nuanced way Going Forward and in a way that preserves privacy and will allow competition so i agree with becca that first of all any privacy vegetation should give authorities to the sec in seconds that our enforcement on the size of the house benefits from the interplay of the competition and Consumer Protection issued and i was at the fordham conference a few weeks ago where we talked on the world and that was the general sentiment that each side informs the other that agency has had or are looking for to close competition and they believe theres a healthy reinforcement and an alignment of issues and i would agree with becca that im relatively about how we structure the new expertise within the agency and we do need more resources when you look at the incredible growth at the economy and essentially stagnation of the number of ftcs we have at the ftc it becomes clear that we are have been outpaced and outmanned and to protect Consumer Privacy and other consumer interests more resources with people. I want to him or that point because something that i would not have appreciated and do not appreciate before i got to the ftc is that when you look from the outside at an impersonal decision you think needs something to be desired part of that analysis you dont see is the staff and commissioners grappling with the question of if we went back and pushed for more what are we giving up to it and what are we not doing instead and some of those decisions even if i dont ultimately agree with them at the end of the day dont come from my sense of while this is good enough and we want to let this company go and they come from a sense of we have nominations across our mission area to protect and if we what more but more into this case we will be leaving both cases on the table in other areas and maybe you disagree but have disagreed but understanding that that analysis with hard looks at budget and play numbers and resort management something i cannot appreciated until i was on the inside of those conversations and its easier to judge on the outside when you dont have a window into what are the cases to moving forward here. One more question before we go out to the audience. You talk about petition and privacy and these are points of overlap or divergence in what do you see as the relationship in privacy and competition policy and vice versa. I will associate myself so my colleagues and i talk about this issue a lot and what he tends to say is competition in privacy is important but privacy is important and we have to think carefully about how this new privacy regime would affect competition and so far i think were both with him but then he tends to go into and therefore we should not have any privacy regime and thats where im like, you have lost me. Much closer to christinas that we have to think about it carefully and i said earlier, follow the money. But this needs advertising is the heart of both these questions and Data Collection is fundamentally about facilitating advertising and advertising, digital Digital Advertising markets are raising important competition questions and looking at that with eyes on is a valuable thing to be doing. We will have questions. On that, please, stand and wait for the microphone and everybody here and cnn can hear the questions. Moving to the aisle first. Then the gentleman behind her. Do you want me to stand as well connect. Yes, please. Thank you. Im several security. Thank you, commissioners for being here. Hopefully you can speak to given the courts recent ruling on restoring the freedom order and the remand on Public Safety how you are thinking about responsible these other Service Providers as in regard to dns and castings and stop what they identified as norman for the inflation service. At a more general level i think we talked about the specifics federal trade Commission Welcomes the ruling in the [inaudible] case. We had authority over broadband isd since they came deep into the marketplace and have brought a number of cases that is not in the bundle of rights and on occasions that get wrapped up into Net Neutrality and to continue to move up the learning curve we have held a hearing on broadband issues within the rubric of the competition and that weve held over the last year. We issued a study to collect information regarding the ways in which we collect and use and protect Consumer Information and so the ftc long as the jurisdiction was removed under the open order and restored to us and we are back on the beat and back to protecting consumers into preventing any competition violation in this space. Perhaps unsurprisingly, i disagree with christine and did not welcome that decision. I thought it was important but Net Neutrality is a good example of where the ftc authority lack of making was a substantial limitation because of where the ftc can be in the past and i dont think weve seen the end of this particular movie. I think it will continue to play out as they consider how to grapple with it and Congress Considers how to grapple with these issues but they are completed and im concerned that our ability to address problematic practices that the effect on consumers is emanated i the ftc act as opposed to the most substantive protections and [inaudible] gentleman in the pink shirt. Hello. Im carl with come daily. When [inaudible] testified last week brought up issues about regulatory capture and i was curious to either of you have concerns about regular tory capture in agencies connect. I have disagreed with some of the Big Decisions that we have had in the past few years but the bases i was a very sincerely i have never thought the agency was captured by any particular company or agency and as i said i thought there were good this agreement about the right way to resolve cases in one nice thing about being a generalist agency, rather than an industry specific agency, is, is it does make us substantially less to capture and if we go brought across the economy that means we dont tend to have that narrow focus on particular industries that other agencies get and that is to our benefit and the benefit of consumers so we should always be on the lookout for regular trait capture or other capture. We should have servants who serve the public. The first and best greatest operation so its something im sensitive to but not candidly something i have seen evidence of. Other questions connect . Over here. Steven with the family Online Safety institute. The childrens online Privacy Protection act is 20 years old and is it up to what it was originally designed for and what is an ideal outcome of this current review . I would say one of the reasons we are doing a rule review is to ensure that recent developments in technology are taken into account with the rule we have and we do have bugs ability to build and guardrails for our new technology as they emerge and as far as what the outcome will be that will be prejudging and neither becca or i would want to enter into. I do think i have questions about whether verifiable parental consent is the only guardrail that we need for children and i understand how it can be valuable and as a pair i appreciate the concept but im not sure it captures the universe and im concerned for children in the Digital Divide a space where children who come from families with fear resources and parents may be less available because theyre working 15 different jobs and i want to make sure we are not depriving those children in committees of protections and that better resource parents are able to provide their children so i think i mentor thats entirely captured at this point so im not sure but i have an open mind at the rulemaking and i think its a good example of how we have will making authority that allows us flexibly we can make sure our rules and guidance is up to speed with technology and we are refreshed more frequently than allegedly the progress but i think we should be honest inches. About where boundaries of our authority lie and call them out if we think they are problemat problematic. Nickel. Thank you commissioners for being here. I want to the back to the point that was made around vulnerable populations. Im curious if the ftc will start again about online bias determination and the role they play is emerging technologies and it makes it harder 25 where theres level of disproportionate impact. Just curious given privacy legislation is now taking on this conversation in a meaningful way terms of algorithmic bias and targeted marketing and emerging technologies can do that and have you thought about that and what jurisdiction will have over that and how you will make determinations of that . As a baseline the federal trade commission has listed these issues particularly in support on big data and so the ftc is on been thinking about and grappling with these issues and has brought cases where the thrust of the business conduct may be to deprive consumers of credit or the ability to get a department and have acted in a way that causes unfortunate outcomes. Backup may have more i think thats right but its something we need to continue to focus on. Some of the decisions become hidden behind our rhythms and are more opaque it is all the more important we try to uncover them where they exist and Pay Attention to them and to me that about general practices and whether they are acceptable and making sure we prioritize our enforcement efforts to reflect an understanding that this kind of harm israel and material to real people. When i talk about databases in the beginning and decisions made for people one of the things i was referring to although i did not set explicitly at the time biased out the rhythmic decisions. They go to all kinds of things that make an honest difference and access to opportunity for real people. That the up shot of hud which is [inaudible] we are coming up against time so lets take any questions that are out there remaining. Once theyre on the aisle and any other takers . Going, going, gone. Please give any wrapup comments. Other than respect to limited resources can you comment on the Lessons Learned in the very slow Government Agency response to cutting out spam . This one over here. Thank you. [inaudible] my question is when aides have drawn up their own legislation on the data Privacy Protection what is your expectation with the federal level which will be coming up next year . Over here on the aisle. American medical association. Curious what the topics we talked about today with a discussion about how certain types of information and what effect and essentially wondering if and federal education there is value in [inaudible] obviously Health Administration is sensitive by many and that would not be covered by hipaa but theres a lot more information that it will be considered Health Information and what would be helpful for the ftc to have we leave this event at this point. You can see it online on a website, cspan. Org. In the search box at the top of the home page type ftc. U. S