Regardless her views representing the official FTC position I thought
this challenge to dogmas of surveillance capitalism by Rebecca Kelly
Slaughter was on the money, and it evidences widespread sentiment in
the US population that supports her ideas.

The first section on "Not just privacy" echos my own thoughts. Privacy
is a too broad and ill-defined term. Labelling some things as "privacy
issues" reduces them to relative personal morals and sweeps other
harms under the rug. She properly terms these broader effects - that
touch on civil liberties, freedom of movement, harms to competition,
misinformation and exploitation - as "data abuses", the same language
I've used in Digital Vegan and in Ethics for Hackers. So I am really
happy to see this gaining usage. Overall though I still think a useful
term is "Digital Dignity" because many of the harms done are hard to
formulate yet seem natural affronts to personal dignity. Later she
touches on the body dysphoria, suicides and other mental health issues
plaguing teenage girls as a result of digital exploitation, but does
not fully link them to the business models of Facebook etc.

In the second section "Notice and Choice Is Not the Answer"
Commissioner Slaughter nicely sums up why simply telling someone that
you are going to harm them, when they have no effective choice or
capacity to extricate, merely adds insult to injury. It is certainly
no excuse or useful legal mechanism. I have long maintained that
"meaningful choice" is absent since most ordinary people, even the
most intelligent and well educated amongst us, effectively lack the
capacity to consent over complex technical issues. Onerous contracts
leveraging general ignorance abound in the digital world.

In a way, section three is really her conclusion, albeit an obvious
one, that "Minimization is a Better Model", but possibly because the
scope of the FTC is limited fails to identify the broader problems of
how abusive technologies are foisted onto people via other agencies,
such as schools, governments and medical services. A more mature
analysis would not blame only commercial data collection, but the
overall societal normalisation of risky behaviours, and poor data
hygiene. That said, I feel she gets the deeper point in saying:

"It should not be necessary to trade one’s data away as the cost of
full participation in society and the modern information economy."

There is much more to this position statement that asserts "The FTC
Can Lead the Way Forward on Data Minimalism", but whether that is
possible or whether technical counter-surveillance and other kinds of
Digital Self-Defence will be needed to beat back surveillance
capitalism remains to be seen. In a sense the problem is that FTC and
similar organisations may see themselves as omnipotent, or over-rate
the effects of regulation. Therefore what I think is missing is a
clear statement from bodies like the FTC that, where they exercise
equity of power they will no longer impede citizens digital self
defence measures, including reverse engineering, cracking and hacking
DRM and keys, or any kind of hacking so long as it is clearly in the
pursuit of protecting ones data, privacy and digital dignity. That
would mean dissolving things like the DCMA of course. It maybe that
USA, being a country that upholds a strong tradition of allowing
people to defend themselves and their property, might lead the way on
this, in different a way from Europe.