Costs and Benefits
In considering the costs and benefits of access and security the Subgroup decided that each should be examined independently for businesses and consumers. In addition to the considerations listed below, the Subgroup believes that secondary costs that may attach to access should be considered. While difficult to quantify, benefits to (individuals) society and (business) commerce due to openness and accountability should be considered. Similarly, while difficult to directly correlate, the costs to businesses and consumers of improper decision-making due to poor data quality should be considered. Such costs may include the failure of the market to offer consumers relevant services and the lost revenue or perhaps even liability costs to businesses of decisions based on data of poor quality.
Where possible, we believe the Advisory Committee, and the Commission, should examine existing data. Online businesses that currently provide access may have information about the benefits and costs of providing it and their experiences with consumers. Other businesses that interact with consumers, and other countries where access is provided, may have information regarding the benefits and costs of providing access.
Many companies have had direct experience with providing access. This includes companies in Europe. Cable companies also provide access. The Advisory committee should gather the experience of these companies to determine what proportion of consumers actually exercise their rights of access. In assessing costs and benefits the Committee should consider whether the costs are justified by the use of the ability to obtain access. In making this assessment, the Committee should try to determine how difficult it may be for consumers to access their personal information held by these companies. The Committee should also evaluate the extent of consumers' knowledge of their right to access such personal information.
Finally , the Committee may need to independently seek out data.
The Subgroup believes that the use of information is an important factor in considering the relative importance of access. For instance, the Committee may consider it more important to ensure that individuals have access to information used to make important decisions, such as the granting of credit, than for data that while retained is not used to make decisions about the individual, such as Web traffic logs.
Business Costs: in assessing the cost to businesses the following variables merit consideration.
Consumer Costs: in assessing the cost to consumers the following variables merit consideration.
Business Benefits: in assessing the benefits to businesses the following variables merit consideration.
Consumer Benefits: in assessing the benefits to consumers the following variables merit consideration.