The draft rules proposed by DHS to implement the Real ID Act are fatally flawed. Focusing on how to best implement an Act as deeply flawed as this one is not in the best interests of individuals or the states; therefore we recommend that the proposed rule be withdrawn. Ultimately, Privacyactivism believes that the Real ID Act should be repealed, but understands that this is outside of the scope of this rulemaking process. Privacyactivism’s comments will therefore focus on the lack of privacy protections in the proposed rule, and why the lack of these protections require the withdrawal of the proposed rule.
Specifically, our comments will cover these areas: 1) The general lack of privacy and security protections; 2) the difficulty of compliance; 3) exceptions in the draft rule that lead to inadequate security; 4) the cost involved.
See our full comments for the details.
Deborah
4 comments:
My comments are here. A few excerpts:
Many of my issues have been covered in more detail by other groups filing comments; for example, the DHS privacy advisory board's comments cover the absolute lack of privacy protection in the regulation; the ACLU discusses issues of individual rights; Governor Butch Otter's mail to you highlights that the unequivocal first priority of REAL ID must be the preservation of personal freedom, commerce and mobility, while protecting the privacy of our citizens and the security of their personal information; PrivacyActivism's comments discuss the difficulty of compliance.
There are two areas where I would like to go into more detail. First of all, as a citizen of a state (Washington) that has decided to opt out of Real ID, I am concerned that despite Real ID's voluntary nature, I will essentially become a second-class citizen, with great difficulty accessing federal buildings to engage in my constitutionally-protected activities. The regulation's requirement of a different color for non-compliant ID strikes me as an extremely unpleasant echo of totalitarian regimes elsewhere. Over time, as Real ID becomes institutionalized, I worry that the loss of my rights will accelerate, and that I'll be subject to discrimination because "I don't have Real ID". I believe that it is DHS's responsibility while promulgating the regulation to put safeguards in place to ensure that this doesn't happen.
Secondly, as somebody with an extensive background in software engineering and computer security (I'm on the National Academies' CSTB panel "Software for Dependable Systems: Sufficient Evidence?") I would especially like to highlight several major risks of the current proposal.
...
While some of the issues I bring up could be addressed by fixes to the proposed regulations, others cannot; and the sum total is enough that the regulations appear to me to be unsalvageable.
For all of these reasons, I ask that the current proposed regulations be withdrawn.
I am sympathetic to the DHS' situation in this matter; because of the wording of the Real ID Act, and the necessary protection of states' rights, in many ways your hands are tied. I would strongly encourage your Department to report back to Congress that the Real ID Act of 2005 cannot be implemented in a way that is compatible with our shared goal of keeping the country more secure, and to request a repeal of the act -- followed by a public debate on how best to implement the 9/11 Comission's recommendation of improving the security of driver's licenses.
My comments (tracking number 80232082) are similar in broad content to the above two, though nowhere near as detailed. But they were filed earlier!
It would be fascinating to know how many emailed comments were sent in. For ease of use, it was definitely number 1.
風俗出勤情報
東京風俗
国立風俗
町田風俗
中野 風俗
池袋風俗
風俗銀座
風俗 汐留
風俗 恵比寿
大塚風俗
風俗 新横浜
市川 風俗
風俗 蕨
大阪風俗
風俗 八王子
風俗 新横浜
風俗 目黒
風俗 池袋
風俗 大和
風俗 汐留
風俗 中野
風俗 銀座
風俗 福生布
風俗 大宮
風俗 市川
柏風俗
大塚風俗
大阪風俗
風俗 北海道
福岡風俗情報
仙台風俗情報
風俗 三河
風俗 三条
融資保証人
就職保証人
賃貸保証人
保証人・就職
逆転送
私書箱センター
私設私書箱
私書箱・東京
福岡私書箱
私書箱とは
私書箱・転送電話
フェイシャル
エステ
リラクゼーション
アロマ
保証人紹介
アリバイ
渋谷エステ
渋谷の賃貸物件
風俗ホームページ作成
風俗ホームページ作成
札幌風俗
青森風俗
秋田風俗
岩手風俗
山形風俗
宮城風俗
福島風俗
群馬風俗
栃木風俗
茨城風俗
新潟風俗
長野風俗
山梨風俗
富山風俗
石川風俗
福井風俗
岐阜風俗
名古屋風俗
静岡風俗
兵庫風俗
京都風俗
滋賀風俗
奈良風俗
三重風俗
和歌山風俗
鳥取風俗
岡山風俗
島根風俗
広島風俗
山口風俗
愛媛風俗
香川風俗
高知風俗
徳島風俗
福岡風俗
大分風俗
宮崎風俗
佐賀風俗
長崎風俗
熊本風俗
鹿児島風俗
沖縄風俗
福岡デリヘルNET福岡風俗情報は風俗総合サイトです。
デリヘル福岡 デリヘル 福岡福岡・博多でデリヘル・デリバリーヘルス・風俗を探すなら福岡デリヘルNET福岡風俗情報をクリック
福岡風俗 福岡 風俗どんどん起こし下さい。
風俗福岡 風俗 福岡
Post a Comment