The Center for Democracy and Technology (CDT) has submitted comments to the National Telecommunications and Information Administration (NTIA) regarding ethical guidelines for research using pervasive data. The submission responds to NTIA's request for input on this subject.

CDT's comments highlight the importance of ethically using pervasive data through independent research, which can help inform technology governance. They suggest that existing ethics guidance is limited and stress the need for advancing ethical research to enhance knowledge and improve user experiences. CDT advocates for government and civil society to explore establishing ethical norms that support rigorous research with pervasive data, benefiting users and society.

The organization outlines several principles in its comments. It suggests considering the unique characteristics and risks associated with specific types of data, acknowledging power imbalances between online services, researchers, and subjects, minimizing legal risks to users when working with pervasive data, and accounting for heightened risks to children involved in such research.

Contributors to CDT's comments include Aliya Bhatia, Nathalie Maréchal, Greg Nojeim, Eric Null, Kate Ruane, and Dhanaraj Thakur.