September 9, 2016 

Via Electronic Mail: cybercommission@nist.gov 

Nakia Grayson 

National Institute of Standards and Technology 

U.S. Department of Commerce 

100 Bureau Drive, Stop 2000 

Gaithersburg, MD 20899 

Re: Input to the Commission on Enhancing National Cybersecurity 

Dear Ms. Grayson: 

The Fashion Innovation Alliance (FIA) submits these comments to the Department of 

Commerce, National Institute of Standards and Technology (NIST) in response to the notice for 

public comment on Information on Current and Future States of Cybersecurity in the Digital 

Economy, published in the Federal Register on August 10, 2016. See 81 Fed. Reg. 52,827 

(August 10, 2016). 

The Fashion Innovation Alliance is a nonprofit trade association representing leaders in fashion 

and technology committed to shaping the future of fashion tech, including smart textiles, 

wearables, e-commerce, and mobile apps. The social and economic value of fashion tech 

continues to expand and is revolutionizing how we live our lives. The U.S. Census Bureau of the 

Department of Commerce announced in August that the e-commerce retail sales estimate for the 

second quarter of 2016 increased 15.8 percent from the same period in 2015.1

 Additionally, 

apparel e-commerce sales in the United States are expected to reach $50.4 billion in 2018.2

 The 

future of fashion tech continues to grow for the wearables market too, which is estimated to be 

worth $25 billion by 2019.3

																																																												

1 Quarterly E-Commerce Retail Sales, Second Quarter 2016, U.S. Census Bureau, U.S. Department of Commerce, 

August 16, 2016, available at https://www.census.gov/retail/mrts/www/data/pdf/ec_current.pdf 2

 E-commerce Apparel Sales to Reach $50.4 Billion, Women’s Wear Daily, Oct. 15, 2015. 3 Wearables Market to Be Worth $25 Billion by 2019, CCS Insight, Aug. 2015, available at

http://www.ccsinsight.com/press/company-news/2332-wearables-market-to-be-worth-25-billion-by-2019-revealsccs-insight.

641	S	Street,	NW	|	3rd FL	|	Washington,	DC	20001

fashioninnovation.org
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The Alliance welcomes the opportunity to share with NIST the state of cybersecurity for fashion 

tech, especially given the emerging technology trends and innovation in e-commerce, mobile, 

and smart accessories and apparel. 

EXECUTIVE SUMMARY 

The digital age has transformed how companies in fashion tech—fueled by strategic partnerships 

and collaborations among technology companies, fashion brands, and startups—deliver products 

and services and help shape customers’ overall shopping experiences. Customers are now able to 

use innovative fashion tech products and digital services to engage with their favorite brands and 

retailers in ways that improve their quality of life. FIA values the security and trust of the 

consumers using fashion tech products and services, and we recommend that government and 

industry continue to work together to strengthen cybersecurity efforts. The Alliance has 

identified below key issues toward encouraging a collaborative approach that will advance 

cybersecurity efforts while also furthering American innovation. 

Internet of Things. The federal government should take a public-private collaborative approach 

in supporting efforts to increase the security of IoT networks and interoperability, while taking 

into account global innovation, industry standards, and best practices. 

Innovative and Inclusive Cybersecurity Workforce for Government and Industry. Cyber 

talent is key to ensuring that both the public and private sectors are not only able to advance 

effective cybersecurity practices, but also make adjustments as technologies and cyber 

challenges evolve. FIA recommends that the public and private sectors continue to work together 

to build an innovative and inclusive cybersecurity workforce through educational and training 

programs. 

The Role of Government in Enhancing Cybersecurity for the Private Sector. The public and 

private sectors should continue to collaborate and work together, building upon the progress of 

the NIST Cybersecurity Framework and other programs. FIA recommends that before 

implementing new rules or regulations, the government should collaborate with the innovators 

developing these technologies in working to address cyber challenges. 

Cybersecurity Resources for Startups. The Alliance recommends that the government expand 

upon its efforts to provide cybersecurity training and business resources for the growing startups 

and entrepreneurs designing fashion tech products and services. The Alliance welcomes NIST’s 

SMB Outreach program and the Federal Trade Commission’s (FTC) Start with Security initiative 

offering guidance for business. 
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DISCUSSION

Internet of Things (IoT) 

Many fashion tech products are connected devices that fall within the category of Internet of 

Things: smart apparel and accessories are connected to sensors detecting heart rate, breathing, 

and other body functions; rings and bracelets are able to link text messages and consumer data 

directly to users’ smartphones and apps. These products are generating significant interest among 

consumers—not only for their ability to track lifestyle activities and ensure connectivity to 

consumers’ smart devices—but also for their sophisticated aesthetics and design. Thus, we must 

continue to advance cybersecurity best practices to keep consumer data safe and secure, while 

building consumer trust and confidence. 

As creative entrepreneurs in fashion tech continue to design new smart accessories and apparel, 

FIA believes that the federal government should continue with voluntary public-private 

partnership efforts established through the NIST Cybersecurity Framework released in February 

2014.4

 The Framework’s flexible approach is suitable for both enterprise technology companies 

entering into the wearable tech arena as well as startups building security into their first 

connected ring or bracelet. 

The Fashion Innovation Alliance also recommends that the federal government take a publicprivate collaborative approach in supporting efforts to increase the security of IoT networks and 

interoperability, while taking into account global innovation and current standards and best 

practices. IoT cybersecurity standards and best practices must include strategies to secure data in 

transit and storage, as well as effective solutions to reduce the amount of time in addressing 

vulnerabilities through patches and other measures. 

Innovative and Inclusive Cybersecurity Workforce 

Cyber talent is key to ensuring that both the public and private sectors are able to implement 

effective cybersecurity practices, especially as the technologies and cyber challenges continue to 

evolve and change. Expanding the cybersecurity workforce has been an ongoing issue in policy 

discussions for a number of years.5

The current challenges for a robust and inclusive cybersecurity workforce are clear. Women 

represent 10% of the cybersecurity workforce, and according to the (ISC)2 2015 Women in 

Security Study, the percentage remained unchanged from 2013-2015.6 Also, it is estimated that 

an additional 1.5 million cybersecurity professionals will be needed by 2020 to accommodate the 

																																																												

4 Framework for Improving Critical Infrastructure Cybersecurity, National Institute of Standards and Technology 

(NIST), February 12, 2014, available at

https://www.nist.gov/sites/default/files/documents/cyberframework/cybersecurity-framework-021214.pdf. 5 Cybersecurity Workforce Assessment Act, Pub. L. No. 113-246 (2014); see also S. 3414, 112th Cong. (2012). 6 (ISC)2 2015 Women in Security Study, available at

https://www.isc2cares.org/uploadedFiles/wwwisc2caresorg/Content/GISWS/2015-Women-In-Security-Study.pdf.
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projected workforce shortfall of cyber talent.7 NIST pointed out in its informational video on the 

Cybersecurity Framework that we will need additional cybersecurity talent.8 

The National Cybersecurity Workforce Framework—launched by the National Initiative for 

Cybersecurity Education (NICE)—provides a useful guide for educating, training, and retaining 

a top cybersecurity workforce.9 FIA recommends that the public and private sectors continue to 

collaborate on ways to build an effective and robust cybersecurity workforce and further expand 

upon related guidance in the NIST Cybersecurity Framework. Public-private partnerships must 

also invest in programs to help recognize and advance cybersecurity talent from all backgrounds. 

For example, startups and fashion brands integrating tech into their platforms have used fashion 

as a way to get more young girls interested in technology, and thus helping to increase the 

pipeline of women in science, technology, engineering, and math (STEM) fields. Fashion tech 

companies rely on information security professionals to help keep customer data transmitted via 

smart accessories and apparel safe and secure. Thus, building an innovative and inclusive 

cybersecurity workforce will be key in protecting such data against cyber intrusions and privacy 

compromises. 

The Role of Government in Enhancing Cybersecurity for the Private Sector 

The public and private sectors should continue to collaborate and work together, building upon 

the work that government and industry have accomplished through the NIST Cybersecurity 

Framework and other programs. FIA also recommends that before implementing new rules or 

regulations, the government should collaborate with the innovators developing the technologies 

working to address cyber challenges. 

Also, given the global reach of digital products and services, FIA welcomes NIST’s current 

outreach efforts to multi-national organizations and foreign governments.10 FIA recommends 

that the federal government evaluate guidance and policy documents developed by international 

organizations before regulating in this area. For example, the EU’s Alliance for Internet of 

Things Innovation (AIOTI) released a policy report in October 2015, which references NIST’s 

Cyber Physical Systems Public Working Group. The report includes a detailed section on 

security, noting the interdependencies of security with privacy, resiliency, and other domains 

while also providing policy recommendations and references to the European Union Agency for 

Network and Information Security, the UK Government Cyber Essentials Scheme, and other 

																																																												

7 (ISC)2 2015 Global Information Security Workforce Study, available at

https://www.isc2cares.org/uploadedFiles/wwwisc2caresorg/Content/GISWS/FrostSullivan-(ISC)2-GlobalInformation-Security-Workforce-Study-2015.pdf. 8 The Cybersecurity Framework Video, U.S. Department of Commerce, NIST, May 23, 2016, available at

https://www.nist.gov/video/cybersecurity-framework. 9 The National Cybersecurity Workforce Framework, available at

http://csrc.nist.gov/nice/framework/national_cybersecurity_workforce_framework_03_2013_version1_0_for_printin

g.pdf. 10 Cybersecurity Framework Feedback: What We Heard and Next Steps, National Institute of Standards and 

Technology (NIST), June 9, 2016, available at https://www.nist.gov/sites/default/files/workshop-summary2016.pdf.
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committees and organizations. 

Cybersecurity Resources for Startups 

The Alliance recommends that the government expand upon its efforts to provide cybersecurity 

training and business resources for the growing startups and entrepreneurs designing innovative 

fashion tech products and services. The Federal Trade Commission’s (FTC) Start with Security

initiative’s guidance for business and NIST’s SMB outreach efforts have served as useful 

resources for startups building security into their products and services. 

FTC staff recently released guidance on how NIST’s Cybersecurity Framework relates to the 

Commission’s data security program.11 As NIST, the National Telecommunications and 

Information Administration, the Department of Homeland Security, the Justice Department and 

other federal entities continue to evaluate cybersecurity policies, the Alliance recommends that 

the agencies coordinate and provide resources and tools on how the various agency documents 

relate to one another. Additional guidance will help to minimize confusion for startups and 

entrepreneurs, allowing more time to advance their innovations. 

Conclusion 

The Fashion Innovation Alliance appreciates the opportunity to submit these comments and 

would be happy to provide you with additional information or clarification. For the reasons 

stated above, the Alliance respectfully requests that the federal government collaborate and work 

with the private sector when considering the current and future states of cybersecurity in the 

digital economy. Any new policies governing cybersecurity for e-commerce and mobile or 

Internet-connected accessories/apparel should consider the broader impact of the digital 

economy as a whole without limiting the innovation powering fashion tech. 

Respectfully submitted, 

Kenya N. Wiley 

Founder and CEO 

Fashion Innovation Alliance 

																																																												

11 FTC Blog Post Outlines How NIST Cybersecurity Framework Relates to FTC Data Security Program, Federal 

Trade Commission, August 31, 2016, available at https://www.ftc.gov/news-events/press-releases/2016/08/ftc-blogpost-outlines-how-nist-cybersecurity-framework-relates.