In 2012, the White House and the FTC both issued reports advocating a new approach to privacy enforcement that can best be described as what?

In 2012, both the White House's "Consumer Privacy Bill of Rights" and the FTC's report "Protecting Consumer Privacy in an Era of Rapid Change" advocated for a more comprehensive approach to privacy. They argued that the traditional sectoral, notice-and-choice model was insufficient for the modern digital economy. They proposed a baseline set of privacy rights that would apply across commercial sectors, representing a significant shift toward a more holistic and comprehensive framework for consumer data protection in the United States.

A. Harm-based: The reports advocated for a consumer rights-based framework, not one that requires a demonstration of concrete harm before protections apply.
B. Self-regulatory: The reports called for stronger legislation and enforcement, moving beyond a purely self-regulatory model, although they did support enforceable codes of conduct.
D. Notice and choice: This is the traditional model that both the White House and FTC reports explicitly identified as insufficient and in need of reform or supplementation.

1. The White House. "Consumer Data Privacy in a Networked World: A Framework for Protecting Privacy and Promoting Innovation in the Global Digital Economy." February 2012, p. 2. The report's stated goal is to articulate a "comprehensive framework."

2. Federal Trade Commission. "Protecting Consumer Privacy in an Era of Rapid Change: Recommendations For Businesses and Policymakers." March 2012, p. i. The report calls for a broader privacy framework to supplement existing sectoral laws.

3. Hoofnagle, Chris Jay. Federal Trade Commission Privacy Law and Policy. Cambridge University Press, 2016, pp. 315-320. DOI: 10.1017/CBO9781316336315. This academic text analyzes the 2012 reports as a significant push for a more comprehensive privacy regime.