Privacy Subteam 

Recommendations

July 2023

Privacy Subteam Members:

Debbie Reynolds

Maria Rerecich

Kevin Kornegay

Mike Bergman

Chair: Debbie Reynolds 

Advisor: Barbara Cuthill

Contractors: Brad Hoehn, Greg Witte

Internet of Things Advisory Board (IoTAB)
DRAFT – U.S. Department of Commerce Internet of Things Advisory Board (IoTAB)

Summary of Recommendations – Privacy Subgroup

R01 - Use Plain Language in Privacy Policies for IoT (approved)

R02 - Establish “Third-Party” Data Sharing and Data Use Policies (approved)

R03 - Create an IoT Privacy Framework for Innovation and Data Protection (approved)

R04 - Include IoT in US Federal Privacy Regulation Proposal Mike Bergman to review

R05 – Create Privacy Transparency for IoT (approved)

R06 - Create IoT-focused educational initiatives for workforce development and 

business, government, and consumer data privacy/trust (approved)

R07 - Promote the implementation of Privacy-Enhancing Technologies (PETs) in IoT 

systems (approved)

2
DRAFT – U.S. Department of Commerce Internet of Things Advisory Board (IoTAB)

Justification

Implementation Barriers

Agencies Federal considerations

R01 - Use Plain Language in Privacy Policies for IoT Approved by the IoTAB July 2023

R01

Use Plain Language in Privacy Policies 

as part of the Federal Acquisition 

Regulation (FAR) requirements per the 

Internet of Things (IoT) Cybersecurity 

Improvement Act of 2020

● Improved understanding of 

Data Privacy policies for 

users, leading to more 

informed decisions when 

using IoT devices 

● Enhanced public trust in IoT 

devices and related 

technologies 

● Simplified policies may lead to 

increased compliance and 

reduced legal disputes 

● Develop guidelines and best practices 

for organizations to follow when 

simplifying privacy policies 

● Establish high-level guidance for 

evaluating and assessing the 

readability of privacy policies

● Coordinate with relevant 

stakeholders, including the private 

sector and business, government, 

and consumer data advocacy groups, 

to ensure widespread adoption

● Resistance from organizations that 

may perceive simplification as a 

limitation on their legal protections

● Possible challenges in defining the 

appropriate level of simplification 

while maintaining accuracy and 

comprehensiveness

● Monitoring and updating the 

simplification guidelines to account 

for technological advancements and 

emerging privacy concerns

● National Institute of 

Standards and Technology 

(NIST)

● Department of Commerce 

(DoC)

● The Office of Management 

and Budget (OMB)

● Office of the National Cyber 

Director (ONCD)

● Procurement: Create requirements for IoT 

providers to implement simplified privacy 

policies for government contracts

● Use National Cybersecurity Strategy 

Implementation Plan July 2013 - Initiative 

Number: 3.2.1 Initiative Title: Implement 

Federal Acquisition Regulation (FAR) 

requirements per the Internet of Things (IoT) 

Cybersecurity Improvement Act of 2020

● Use National Cybersecurity Strategy 

Implementation Plan July 2013 -Initiative 

Number: 1.1.1 Initiative Title: Establish an 

initiative on cyber regulatory harmonization

● Plain Writing Act of 2010" (Public Law 111-274)

3
DRAFT – U.S. Department of Commerce Internet of Things Advisory Board (IoTAB)

Justification

Implementation Barriers

Agencies Federal considerations

R02 - Establish “Third-Party” Data Sharing and Data Use Policies

Approved by the IoTAB July 2023 R02

Establish clear policies for thirdparty data sharing and IoT device 

data use

● Increased interconnectivity 

and data-sharing capabilities 

of IoT devices present 

significant privacy risks.

● Policies safeguard users' 

personal data and ensure 

transparency.

● Clear policies foster trust and 

encourage IoT adoption.

● Create guidelines on how to 

effectively communicate thirdparty data sharing and data use 

in privacy policies

● Implement public awareness 

campaigns about these policies 

to educate users about their 

data rights

● Resistance from IoT companies 

who rely on third-party data 

sharing for business operations

● Challenges in aligning these 

policies with existing privacy 

regulations and international 

data protection standards

● National Institute of Standards 

and Technology (NIST)

● Federal Trade Commission (FTC)

● Department of Energy (DOE)

● United States Department of 

Agriculture (USDA)

● Office of the National Cyber 

Director (ONCD)

● Policies & Frameworks: Work with industry 

leaders to establish data use guidelines for 

Third-Party” Data Sharing and Data Use 

Policies

● Use National Cybersecurity Strategy 

Implementation Plan July 2013 -Initiative 

Number: 1.1.1 Initiative Title: Establish an 

initiative on cyber regulatory harmonization

● Use National Cybersecurity Strategy 

Implementation Plan July 2013 - Initiative 

Number: 1.1.3 Initiative Title: Increase 

agency use of frameworks and international 

standards to inform regulatory alignment

4
DRAFT – U.S. Department of Commerce Internet of Things Advisory Board (IoTAB)

Justification

Implementation Barriers

Agencies Federal considerations

R03 - Create an IoT Privacy Framework for Innovation and Data Protection

Approved by the IoTAB July 2023 R03

Develop an IoT Privacy Framework 

for Innovation and Data 

Protection specifically tailored to 

the unique challenges posed by 

IoT devices

● Provides a consistent, unified 

approach to Data Privacy and 

security in the IoT sector, reducing 

confusion and fragmentation for 

business, government, and 

consumers

● Several US States have passed 

comprehensive privacy laws, and 

several other states are in the 

process of advancing privacy 

legislation.

● Encourages innovation by providing 

clear guidelines and expectations for 

IoT device manufacturers, fostering 

a competitive and growth-oriented 

environment

● Incorporate lessons learned from 

existing privacy regulations, such 

as the CCPA and GDPR, to create a 

more effective and efficient 

framework

● Ensure that the framework is 

adaptable and scalable to 

accommodate the rapidly evolving 

nature of IoT technology and the 

Data Privacy Landscape

● Balancing between protecting business, 

government, and consumers’ Data Privacy 

and fostering innovation in the IoT sector

● Providing resources, guidance, and support 

to businesses for the adoption and 

implementation of the IoT Privacy 

Framework

● Reviewing and updating the IoT Privacy 

Framework to ensure it remains relevant 

and effective in addressing emerging Data 

Privacy challenges and technological 

advancements

● National Institute of 

Standards and Technology 

(NIST)

● Partnership: Develop the IoT Privacy Framework 

in partnership with industry and privacy experts 

● Working with US States: Collaboration with US 

States who have already passed privacy laws or 

are in the process of advancing legislation would 

be key for regulatory alignment

● Use National Cybersecurity Strategy 

Implementation Plan July 2013 -Initiative 

Number: 1.1.1 Initiative Title: Establish an 

initiative on cyber regulatory harmonization

● Use National Cybersecurity Strategy 

Implementation Plan July 2013 - Initiative 

Number: 1.1.3 Initiative Title: Increase agency 

use of frameworks and international standards 

to inform regulatory alignment

5
DRAFT – U.S. Department of Commerce Internet of Things Advisory Board (IoTAB)

Justification

Implementation Barriers

Agencies Federal considerations

R04 - Include IoT in US Federal Privacy Regulation Proposal

Mike Bergman to review R04

Add IoT Data Retention Transparency: 

Establish guidelines for manufacturers 

to establish clear policies on how long 

business, government, and consumer 

data is retained

● Supports contemplated federal legislation 

e.g., American Data Privacy and Protection 

Act (ADPPA) H. R. 8152 legislation

● Adds IoT-specific language to the ADPPA 

related to IoT Data Retention Transparency

● Ensures that IoT device manufacturers 

share a consistent set of privacy standards, 

enhancing business, government, and 

consumer data trust and protection

● Facilitates innovation by providing clear 

guidelines and expectations for IoT 

businesses, fostering a competitive and 

growth-oriented environment

● Use contemplated legislation 

(e.g., the American Data Privacy 

and Protection Act, or ADPPA) 

addresses emerging Data Privacy 

challenges and technological 

advancements related to IoT

● Achieving consensus among stakeholders and 

state-level regulators on the most effective 

elements and practices to incorporate into the 

Federal Privacy legislation

● Ensuring compatibility with existing national 

and international privacy regulations

● Balancing between protecting business, 

government, and consumer Data Privacy and 

fostering innovation in the IoT sector

● Providing resources, guidance, and support to 

businesses for the adoption and 

implementation of the IoT specific guidelines

● Congress

● Department of Commerce 

(DoC)

● National Institute of 

Standards and Technology 

(NIST)

● Federal Trade Commission 

(FTC)

● Legislation: Support IoT addition 

to contemplated Federal Data 

Privacy legislation (e.g., the 

American Data Privacy and 

Protection Act, or ADPPA)

6
DRAFT – U.S. Department of Commerce Internet of Things Advisory Board (IoTAB)

Justification

Implementation Barriers

Agencies Federal considerations

R05 – Create Privacy Transparency for IoT 

Approved by the IoTAB July 2023 R05

Develop and implement a privacy 

transparency system for IoT devices, 

using the “U.S. Cyber Trust Mark” for 

business, government, and consumer 

data for Connected Devices and other 

transparency programs as a guide

● Empowers businesses, 

governments, and consumers to 

make informed decisions about 

IoT devices based on their privacy 

features and practices

● Encourages IoT device 

manufacturers to prioritize 

privacy, fostering competition and 

innovation in privacy-enhancing 

technologies

● Enhances overall Cybersecurity 

and data protection by promoting 

greater business, government, 

and consumer data awareness of 

privacy practices

● Consider input from privacy experts, 

industry stakeholders, and business, 

government, and consumer data advocacy 

groups to develop privacy transparency, 

including content and design

● Develop guidelines and standards for 

privacy transparency, including required 

information, format, and or product 

information

● Encourage IoT device manufacturers to 

adopt privacy transparency and provide 

resources to help them align with the new 

recommendations

● Ensuring broad adoption and compliance 

with the privacy transparency system 

across different industries and sectors

● Incentivizing IoT device manufacturers who 

may perceive privacy transparency as 

burdensome, costly, or restrictive

● Balancing the need for comprehensive 

privacy information with simplicity and 

ease of understanding for businesses, the 

government, and consumers

● Department of Commerce 

(DoC)

● National Institute of 

Standards and Technology 

(NIST)

● Federal Trade Commission 

(FTC)

● Promotion: Publicize the benefits of IoT 

privacy transparency 

● Partnership: Work with industry leaders to 

develop privacy transparency 

● Use National Cybersecurity Strategy 

Implementation Plan July 2013 -Initiative 

Number: 1.1.1 Initiative Title: Establish an 

initiative on cyber regulatory harmonization

● Use National Cybersecurity Strategy 

Implementation Plan July 2013 - Initiative 

Number: 3.2.2 Initiative Title: Initiate a U.S. 

Government IoT security labeling program 

“U.S. Cyber Trust Mark”

7
DRAFT – U.S. Department of Commerce Internet of Things Advisory Board (IoTAB)

Justification

Implementation Barriers

Agencies Federal considerations

R06 - Create IoT-focused educational initiatives for workforce development and business, government, 

and consumer data privacy/trust

Approved by the IoTAB July 2023 R06

Develop educational initiatives that 

include IoT, targeting workforce 

development, and enhancing 

business, government, and consumer 

data privacy and trust

● Increase in the understanding 

and safe use of IoT 

technologies

● Development of a highly 

skilled workforce capable of 

addressing IoT privacy 

challenges

● Boosting business, 

government, and consumer 

data trust and adoption of IoT 

devices and services

● Defining the scope and content of educational 

initiatives

● Identifying key target audiences (schools, 

universities, businesses, general public)

● Collaborating with educational institutions and 

industry leaders

● Ensuring the relevancy and practicality of the 

educational content

● Regularly updating the initiatives to keep pace 

with technological changes

● Workforce development to encompass 

personas, including manufacturers, 

Implementers, service providers, and workers.

● Difficulty in keeping up with the 

fast-paced advancements in IoT

● Challenges in reaching and 

engaging the targeted audiences

● Securing sufficient funding and 

resources

● National Institute of 

Standards and Technology 

(NIST)

● Office of the National Cyber 

Director (ONCD)

● Promotion & Education: Publicize the 

importance of IoT education and promote 

the adoption of educational programs for 

workforce development and business, 

government, and consumer data trust 

● Use National Cybersecurity Strategy 

Implementation Plan July 2013 - Initiative 

Number: 4.6.1 Initiative Title: Publish a 

National Cyber Workforce and Education 

Strategy and track its implementation

8
DRAFT – U.S. Department of Commerce Internet of Things Advisory Board (IoTAB)

Justification

Implementation Barriers

Agencies Federal considerations

R07 - Promote the implementation of Privacy-Enhancing Technologies (PETs) in IoT systems

Approved by the IoTAB July 2023 R07

Promote the implementation of 

Privacy-Enhancing Technologies 

(PETs) in IoT systems

● PETs protect privacy while 

extracting valuable insights from 

the vast IoT data

● They align with responsible data 

use without compromising user 

privacy

● PETs support broader U.S. goals of 

leveraging technology for societal 

benefits

● Their use fosters trust and 

promotes acceptance of IoT 

solutions

● Implementation of PETs can 

prevent data breaches and 

associated legal issues

● Ensuring robust security measures for PETs 

to prevent unauthorized data access

● Conducting comprehensive technical and 

ethical evaluations of PETs before their 

adoption

● Enhancing public understanding and Trust 

in PETs

● Encouraging interoperability between 

different PETs systems

● Establishing a framework for monitoring 

the effectiveness and impacts of PETs in IoT

● Limited technical expertise to 

understand, implement, and 

manage PETs

● Possible resistance from private 

sectors due to perceived risks or 

costs

● The complexity of developing 

universally accepted privacy 

standards for IoT

● The Office of Science and 

Technology Policy (OSTP)

● National Institute of 

Standards and Technology 

(NIST)

● Internet of Things (IoT) Cybersecurity 

Improvement Act of 2020

● The White House’s Advancing a Vision for 

Privacy-Enhancing Technologies proposal 

(June 2022)

● Use National Cybersecurity Strategy 

Implementation Plan July 2013 - Initiative 

Number: 1.2.1 Initiative Title: Scale publicprivate partnerships to drive development 

and adoption of secure-by-design and 

secure-by-default technology

9