Access to TRUSTe complaint data
- Request to:
- Law used:
- Status of this request:
- Request awaits classification
- Summary of Request
- Dear TRUSTe,
Over the past few months, I have filed a slew of Privacy Shield and Safe Harbor complaints with TRUSTe as arbitration mechanism.
TRUSTe uses Zendesk, one of the best customer service tools. Zendesk is equipped with a lot of very useful APIs both on the customer side and on the representative side. In request #49340, I have asked TRUSTe to open up some of the APIs to Zendesk, to facilitate my use of TRUSTe's Zendesk instance. This request was refused.
Since, TRUSTe has decided to refuse opening a bunch of other (unrelated) complaints, all about Facebook. In your systems, these were: #49616, #49618, #49143, #49141, #49138, #49621, #49622, #49620, #49617, and #49140.
The basis for the refusals is, in all those cases, the result of a consultation that apparently took place between Facebook and TRUSTe, whose content I have not been informed about. In each case it is claimed by TRUSTe, following Facebook's opinion, that Facebook Ireland should be contacted instead. While Facebook has been offered the chance by TRUSTe to argue (privately) why my complaint does not allegedly fall within the scope of the Privacy Shield mechanism, I have not even been offered the chance by TRUSTe to argue the opposite claim. Instead, my complaint was deemed "ineligible for resolution by TRUSTe", and the "determination [made that the complaint] is not eligible for appeal via [the TRUSTe] Appeals Process".
According to me, the whole thing is thus simultaneously:
- a matter of systematic deceptive practice relevant to the FTC;
- a matter of relevance to the Data Protection Authorities;
- a matter of relevance for the EU Commission and the Swiss government in assessing the efficacy of the Privacy Shield mechanisms.
Unfortunately, by now, a lot of relevant data is held by TRUSTe in their systems. I can do some cut and paste, but the results would not be satisfactory.
In consequence, I am now asking, under the purview of the "Privacy Shield" arrangement which is applicable to TRUSTe
for a copy of all my personal data, where "personal data" is scoped by the EU Data Protection Directive to include:
all the conversations that took place around the tickets listed above, including conversations held on TRUSTe's Zendesk system _as well as_ the communications that took place, possibly elsewhere or in some kind of Zendesk "private mode", between TRUSTe and Facebook regarding my complaints.
You will find a link to my identification documents below my signature.