Electronic Privacy Information Center
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Electronic Privacy Information Center (EPIC) is a nonprofit research and advocacy center established in 1994. It works on privacy, freedom of expression and democratic values through litigation, public-records requests, research and policy advocacy. Its AI work concerns both government systems and commercial tools that classify, score or make decisions about people.[1]
Institutional role
EPIC files amicus briefs, pursues access to government records, submits complaints and petitions to regulators and advises lawmakers. Its stated approach connects privacy with freedom from discriminatory data practices and meaningful oversight. It identifies a board of directors and an advisory board with expertise in law, technology and public policy.[1]
Its commercial-AI program addresses uses in employment, housing, finance and other consequential settings, as well as consumer-facing products. It advocates limits on data collection, transparency, accountability and protections against discrimination. These activities span proposed rules and enforcement of existing protections; an EPIC complaint is an advocacy intervention requesting official action, not an agency determination that its allegations are correct.[2]
Boston University’s biography of Woodrow Hartzog lists his service on EPIC’s advisory board. This is an advisory affiliation, distinct from executive leadership.[3]
HireVue complaint
In November 2019, EPIC asked the Federal Trade Commission to investigate HireVue's candidate-assessment practices. The complaint alleged unfair and deceptive uses of biometric information and opaque algorithms. It argued that applicants could not meaningfully understand or challenge their assessments and questioned claims about what the systems could infer from applicants' characteristics.[4]
EPIC requested an investigation, a halt to scoring pending substantial changes and disclosure of the basis for individual evaluations. It also urged adherence to the OECD AI Principles and Universal Guidelines for AI. These were the remedies EPIC sought, rather than remedies shown here to have been ordered. The complaint concerns the practices described in 2019 and should not be treated as a description of HireVue's current products. Its policy significance is the attempt to translate transparency and fairness principles into a consumer-protection enforcement theory.[4]
Petition for commercial-AI rulemaking
EPIC's legal-document record dates its FTC rulemaking petition to February 3, 2020. The petition asked the commission to address AI in commerce using its trade-regulation authority. It followed earlier complaints involving employment assessments and scoring of young athletes and formed part of a broader campaign for algorithmic transparency.[5]
The petition argued that widespread use of consequential, opaque systems required rules rather than reliance only on individual enforcement cases. It linked AI principles to the FTC's authority over unfair and deceptive practices and sought clearer expectations concerning transparency, accountability and remedies. The document discusses decisions affecting housing, credit, employment and other areas of consumer life.[6]
Its central legal claim is that the commission could use existing statutory authority to define prohibited practices more clearly. That is the petitioner's interpretation and request. Filing the document did not itself create a binding AI rule or convert every voluntary principle it cited into an enforceable obligation. The record is useful for tracing the development of consumer-protection arguments before the more recent focus on generative AI.[6]
Funding and governance
EPIC identifies itself as a 501(c)(3) organization and says it accepts no corporate or government sponsorships. Its public nonprofit page provides links to tax filings, audited financial statements and annual reporting. This disclosure policy is relevant to its institutional relationships, but the absence of sponsorship does not by itself resolve substantive disputes about its legal positions.[7]
Selected contributions
- FTC complaint concerning HireVue candidate assessments (November 2019).[4]
- Petition for commercial-AI trade regulation (February 2020).[5]
- Continuing commercial-AI advocacy connecting privacy, data minimization and discrimination concerns.[2]
October 2026: Spirit employee-data privacy brief
In a brief dated October 1, 2026, EPIC and Professor Seema N. Patel supported the Association of Flight Attendants-CWA's limited objection to a proposed employee-data sale in Spirit Aviation Holdings' Chapter 11 proceedings. EPIC's October 2 announcement reported the filing and identified Harvard Law School's Cyberlaw Clinic as representing the amici.[8]
The brief argued that consumer-focused deidentification promises inadequately protected workers, that reidentification and sensitive attribute inference could expose confidential information, and that monetizing workplace records would encourage excessive collection and retention. The amici asked the court to exclude the challenged employee data or require stronger safeguards and greater worker control. These are the amici's arguments and requested relief. The signed document identifies case 25-11897 (SHL) in the Southern District of New York.[9] See October 12 news archive coverage.
In an October 12 article, EPIC lawyers Abigail Kunkler and Mayu Tobin-Miyaji described continuing negotiations to exclude sensitive records and deidentify other employee data, while arguing that reidentification risks remain. The authors are counsel involved in the advocacy.[10]
October 2026: AI-training web-scraping consultation
In an October 30 announcement, EPIC said it submitted comments on the European Data Protection Board's draft guidelines on web scraping to train generative AI. It urged inclusion of data brokers, stronger limits on reliance on legitimate interests, a public registry of training-data users, affirmative website permission and clearer requirements for cleaning training datasets. These are EPIC's recommendations and legal arguments, rather than adopted EDPB requirements or a determination that a particular developer acted unlawfully.[11] See October 31 news coverage.
Related articles
- October 12 News: EPIC challenges proposed Spirit worker-data sale for AI training
- Policy
- Center for Democracy & Technology
- Public Citizen
- AI Now Institute
References
- ↑ 1.0 1.1 1.2 1.3 EPIC, About Us. Accessed September 12, 2026.
- ↑ 2.0 2.1 EPIC, Commercial AI Use. Accessed September 12, 2026.
- ↑ Boston University School of Law, Woodrow Hartzog, faculty biography and bibliography. Accessed September 12, 2026.
- ↑ 4.0 4.1 4.2 EPIC, FTC Complaint Concerning HireVue, November 6, 2019. Accessed September 12, 2026.
- ↑ 5.0 5.1 EPIC, AI Rulemaking Petition and Legal Documents. Accessed September 12, 2026.
- ↑ 6.0 6.1 EPIC, Petition for FTC Rulemaking Concerning AI in Commerce, February 2020. Accessed September 12, 2026.
- ↑ EPIC, Being a Non-profit. Accessed September 12, 2026.
- ↑ EPIC, EPIC Files Amicus Brief Challenging Spirit Airlines’ Bankruptcy Sale of Employee Data to Google, October 2, 2026.
- ↑ EPIC and Seema N. Patel, Proposed Brief of Amici Curiae in Support of the Association of Flight Attendants-CWA, AFL-CIO’s Limited Objection, October 1, 2026, signed brief, pp. 1–16.
- ↑ Abigail Kunkler and Mayu Tobin-Miyaji, Tech Policy Press, “Spirit Airlines Is Selling Its Workers’ Data. That Can’t Fly,” October 12, 2026; full article reviewed.
- ↑ Calli Schroeder, EPIC, “EPIC Comments to EDPB on Guidelines on Web Scraping for AI: Go Further,” October 30, 2026; complete announcement reviewed.