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Access to TRUSTe complaint data

Request to:
TRUSTe
Law used:
Privacy Shield
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 https://www.privacyshield.gov/partici... 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.

Messages in this request

From << Name Not Public >>
Subject Access to TRUSTe complaint data [#137]
Date May 3, 2017, 9:45 p.m.
To TRUSTe
Status Awaiting response

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 https://www.privacyshield.gov/partici... 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.
[... Show complete request text] Kind Regards, << Name Not Public >>
  1. 3 months, 2 weeks agoMay 3, 2017, 9:45 p.m.: << Name Not Public >> sent a message to TRUSTe.
From Joanne Furtsch – TRUSTe
Subject Re: Access to TRUSTe complaint data [#137]
Date May 5, 2017, 8:12 p.m.

Dear Mr << Name removed >> - I am writing to confirm receipt of your letter dated May 3, 2017. We will follow up with you once we have reviewed your request. Regards, Joanne Furtsch Director, Policy and Data Governance <<email address>> On Wed, May 3, 2017 at 12:45 PM, << Name removed >> << Name removed >> < <<email address> > wrote: > 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 > https://www.privacyshield.gov/partici... > Active > 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. > > << Name removed >> << Name removed >> > <<email address>> > > P ost Address: > << Name removed >> << Name removed >> > << Address removed >> > > -- > Legal Note: This mail was sent through a Data Protection Portal. Replies > might be published automatically. > > > > >
  1. 3 months, 1 week agoMay 5, 2017, 8:12 p.m.: Received an email from TRUSTe.
From Joanne Furtsch – TRUSTe
Subject Re: Access to TRUSTe complaint data [#137]
Date May 22, 2017, 5:38 p.m.
Attachments

Dear Mr. << Name removed >> , This message is in response to your access received by TRUSTe on May 3, 2017. We continue to research our response and will provide a further update with information. However, initially we wanted to check whether you can access the consumer view of your tickets via Zendesk. The Zendesk interface allows users to log in and look at the consumer view of their tickets on a self-help basis at: https://feedback.truste.com/hc/en-us/... This consumer view includes allowing you to view the zip files and any other attachments you sent to us via our Zendesk system. Please let us know if you have any trouble logging in and viewing the information that is available via this method. Unless we hear otherwise, we will focus our research on other aspects that may relate to your request. Regards, Joanne Furtsch Director, Policy & Data Governance <<email address>> On Fri, May 5, 2017 at 11:12 AM, Joanne Furtsch < <name and email address> > wrote: > Dear Mr << Name removed >> - > > I am writing to confirm receipt of your letter dated May 3, 2017. We will > follow up with you once we have reviewed your request. > > Regards, > Joanne Furtsch > Director, Policy and Data Governance > <<email address>> > > On Wed, May 3, 2017 at 12:45 PM, << Name removed >> << Name removed >> < > <<email address> > wrote: > >> 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 >> https://www.privacyshield.gov/partici... >> AAG&status=Active >> 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. >> >> << Name removed >> << Name removed >> >> <<email address>> >> >> P ost Address: >> << Name removed >> << Name removed >> >> << Address removed >> >> >> -- >> Legal Note: This mail was sent through a Data Protection Portal. Replies >> might be published automatically. >> >> >> >> >> > >
-- *Joanne B. Furtsch, CIPP/US/C* Director, Policy and Data Governance <<email address>> | o: 415-520-3409| m: 916-212-7903 [image: Inline image 1]
  1. 2 months, 3 weeks agoMay 22, 2017, 5:39 p.m.: Received an email from TRUSTe.
From << Name Not Public >>
Subject Re: Re: Access to TRUSTe complaint data [#137]
Date June 13, 2017, 12:21 p.m.
To TRUSTe

Dear TRUSTe, I do have access to my account. However, as described originally this does not provide me with an easy opportunity to export the content of conversations. It also would not give me access to bilateral conversations that took place between Facebook and TRUSTe. Sincerely yours << Name removed >> << Name removed >> Request Number: 137 Reply To: <<email address>> Post Address: << Name removed >> << Name removed >> << Address removed >>
-- Legal Note: This mail was sent through a Data Protection Portal. Replies might be published automatically.
  1. 2 months agoJune 13, 2017, 12:21 p.m.: << Name Not Public >> sent a message to TRUSTe.