The National Community Pharmacists Association (NCPA) welcomes the opportunity to provide comments to the Federal Trade Commission on the “Trade Regulation Rule on Commercial Surveillance and Data Security.” NCPA is well positioned to comment on the necessity of rules that would clarify and make fair the ways in which companies can collect, aggregate, use, transfer, share, sell or otherwise monetize data. Specifically, NCPA can provide insights that reflect the realities of how data is used in a way that is unfair and deceptive in the pharmacy industry and that will guide the Commission in identifying and proscribing harmful, unlawful, and anticompetitive practices.
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