Facebook Fails to Address Privacy Concerns, as Powerful Canadian Complaint Documents

They ought to change the name of a corporate position entitled chief privacy officer to chief data collection protector. That’s our response to the comment from Facebook’s Chris Kelly, who serves as its chief privacy officer. According to the Associated Press, Mr. Kelly responded to the privacy complaint filed by the Canadian Internet Policy and Public Interest Clinic (CIPPIC) with the following comment: “We’ve reviewed the complaint and found it has serious factual errors — most notably its neglect of the fact that almost all Facebook data is willingly shared by users…”

We find such a remark incredibly revealing about Facebook, and it raises questions about how well they have structured the role of its “chief privacy officer.” For example, does Mr. Kelly believe that Facebook users understand, as pointed out in the very important CIPPIC complaint on page 22, that outside developers are given access to a wide range of user information. As the complaint notes:

“(a) Information That May Be Provided to Developers. In order to allow you to use and participate in Platform Applications created by Developers, Facebook may from time to time provide Developers access to the following information: (i) any information provided by you and visible to you on the Facebook Site, excluding any of your Contact Information, and
(ii) the user ID associated with your Facebook Site profile.
(b) Examples of Facebook Site Information. The Facebook Site Information may include, without limitation, the following information, to the extent visible on the Facebook Site: your name, your profile picture, your gender, your birthday, your hometown location (city/state/country), your current location (city/state/country), your political view, your activities, your interests, your musical preferences, television shows in which you are interested, movies in which you are interested, books in which you are interested, your favorite quotes, the text of your “About Me” section, your relationship status, your dating interests, your relationship interests, your summer plans, your Facebook user network affiliations, your education history, your work history, your course information, copies of photos in your Facebook Site photo albums, metadata associated with your Facebook Site photo albums (e.g., time of upload, album name, comments on your photos, etc.), the total number of messages sent and/or received by you, the total number of unread messages in your Facebook in-box, the total number of “pokes” you have sent and/or received, the
total number of wall posts on your Wallâ„¢, a list of user IDs mapped to your Facebook friends, your social timeline, and events associated with your Facebook profile.”

Whoa! Do users really know this and give away their data consciously? We think not. Our friends from Up North have ignited a campaign which will grow throughout the world.

Time Warner’s Plans for Bebo: Better Targeting, Engagement & Monetization of 13-24 year olds, esp. in EU

Time Warner’s AOL, which now owns Bebo, will be focusing the site to better target the 13-24 year old demographic. Now part of the Platform A online ad system, Bebo will help support AOL’s European plans, enhancing its ability to “engage” youthful users. As reported by paidcontent.org, “Bebo’s engagement marketing will be melded with AOL’s Platform A.” Bebo’s Joanna Shields explained that “[I]n the UK, the 13-24 year olds are watching less and less television… if you’re trying to reach the young demographic, you have to reach them in the language in which they’re interacting with these sites.” Paidcontent noted that Ms. Shields “touted the redesign of AOL to make the various sites more appealing to youth, which has caused an increase in engagement.”

Bebo is at the core of AOL/Platform A’s international expansion plans. By combining Platform A’s data collection and targeting apparatus with Bebo’s appealing content for youth, paidcontent suggested that Time Warner hoped that “…the opportunity to monetize the site may be superior than what it’s been at other social nets.”

European Privacy Officials investigate behavioral targeting & data mining

Just to place the privacy and online marketing debate in better perspective. It is appropriate and necessary for lawmakers and policymakers to examine and then address through rules the impact of new technologies on privacy. The Article 29 Working Party, the EU’s data protection review group, adopted as part of its 2008-2009 work plan to help ensure “data protection in relation to new technologies.” Among the areas they are now examining include: “search engines, on-line social networks (especially for children and teenagers), behavioural profiling, data mining, [and] digital broadcasting” (they are also focusing on ICANN and WHOIS). Direct Marketing is being reviewed as well.

Our point here is that the online industry has largely developed its system of data collection without user permission largely in the absence of thoughtful oversight that would ensure privacy. We believe the process underway in the EU will help address this issue in a meaningful way.

MySpace expands ability for marketers to track and target "community" members

MySpace has launched what it calls its “community builder platform for [the] advertising community.” Here’s what they say it does (our emphasis):

The new platform gives MySpace advertisers the ability to build, maintain and customize brand profiles while also providing guaranteed valuable analytics to help them gauge campaign performance and make real-time adjustments to maximize effectiveness. The platform is currently being beta tested by Deep Focus

“Community Builder allows our clients to connect with potential brand evangelists in an unprecedented way,” said Ian Schafer, CEO of Deep Focus. “The flexible platform provides access to solutions and value propositions that enable brands to engage with a new generation of consumers and the freedom to update and manage communities in real-time. It’s a powerful tool that can help build community literally — and figuratively.”

The Community Builder advertising platform will be available in the US and builds upon MySpace’s industry leading advertising model, which includes customized communities, multi-platform integrated marketing campaigns, and the new advertising platforms HyperTargeting and SelfServe which empower users such as small business owners, bands, and politicians to purchase, create and analyze the performance of ads throughout the MySpace network.”

Red Herring reports that “… Community Builder…allows marketers to analyze the impact of their online ad effort and respond to it by doing things like updating blogs, studying finely tuned traffic data, changing videos, shifting ads, or testing messages…“One of the major complaints about social network ads has been the metrics, as marketers complain that they have no return on investment to show for their campaigns,” said Ian Schafer… “This gives us 24/7 access to the process of building communities.”

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Yahoo! wants politicians to use Behavioral Targeting to target voters–Privacy and voter manipulation ethics ignored

Yahoo! is urging elected political officials and campaigns to use the arsenal of online advertising tools, despite the questions such dubious techniques raise on privacy and other consumer protection issues. Here’s an excerpt from a Yahoo! VP for political ads piece urging pols to embrace behavioral targeting. From Politics magazine online:

“Use the Internet as a more efficient, less expensive channel to reach voters with certainty… political campaigns are about seven years behind the private sector in their use of the Internet as a paid media vehicle…campaigns can make the web work harder for them by using online display media…Our studies indicate that a targeted ad based on geography or demographics can increase response rates by 50 percent. And when ads are targeted based on behavior, those rates increase to 66 percent. These are campaigns based on certainty-whereby a specific audience is messaged to and managed to produce a desired result. This is true whether it’s a campaign to acquire donations or e-mail addresses, or a persuasion or get-out-the-vote message. Moreover, the results can be seen in just hours or days, letting you keep doing what works and kill what doesn’t…the real opportunity is to use the Internet as a paid media platform to run, track and move persuasion metrics.”

Here’s Your Real Online Advantage … And No, It’s Not Viral Videos. Richard J. Kosinski. Politics. 4/1/08

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Former journalist and now online ad industry lobbyist Randall Rothenberg, in a BusinessWeek commentary, suggests that the call for privacy rules ensuring individuals have control over their data will undermine the Internet. You would think a Madison Ave. trade group could craft more creative PR copy. But the online ad industry’s position is indefensible, since they built a system based on the harvesting of our information without believing they would need to get our permission first. The IAB board should realize it has embarked on a very dangerous campaign here that will undermine credibility for many marketers. Here’s my response submitted to BusinessWeek:
Mr. Rothenberg, as head of the interactive ad trade group lobbying against the call from consumer groups for the government to protect personal privacy online, fails to address the central question regarding online advertising. The call for regulation is designed to ensure individuals control their data while on the Internet or using their mobile phones—not companies such as Google, Microsoft, and AOL. Public interest groups are not opposed to interactive marketing: indeed, we recognize it as a key source of funds for online publishing. But Mr. Rothenberg’s members have created a commercial surveillance system that rivals the NSA—tracking and analyzing our every move while on the Internet, all so we can be encouraged to behave favorably to some marketing message. Responsible ad industry leaders will seriously address the privacy threats created by the interactive marketing apparatus—and not hide behind self-serving claims that unless our privacy is lost, we won’t have a robust digital medium.

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BT Watch: Social Networks & Behavorial Targeting: “people, not pages” are tracked

excerpt from interview with Andrew Monfried, founder and CEO of Lotame Solutions]: “One of the biggest challenges is that the industry is trying to apply standard behavioral targeting techniques to the robust arena of user-generated content and social media. Emphasis is still placed on contextual relevance when, in reality, that metric doesn’t take into account true behavior and consumer interests. People are commenting, uploading, posting, viewing videos, and using widgets. The key is to leverage this data in a way that will drive performance. Contextual relevancy doesn’t capture those verbs or actions….One of the most critical things moving forward is understanding that within social media, click-through rates aren’t the most accurate measurement of success. A truly engaged user is more valuable than a click… The industry will need to embrace new ad units as well as leverage behavioral targeting as a new way to distribute content…Our technology gathers tremendous amounts of data inherent to user-generated content, and we use this to build targeted and customizable audiences as well as provide monetization solutions. For example, if a brand wants to target consumers who only like The Grateful Dead, we build that exact audience for them… Lotame allows advertisers to touch people and not pages….

Social Networking Meets Behavioral Targeting. Anna Papadopoulos. clickz. March 26, 2008

CDD Publishes new report on widgets, third-party apps: "The Facebook Economy"

My CDD commissioned a report from investigative journalist Adam Mayle that examines Facebook and the growing universe of third-party applications. The report, available via here, examines some of the data collection and privacy issues from these Facebook-related services.

Here’s a short excerpt: “But while this platform has benefited many, it raises concerns about user privacy. Because of their deep integration into Facebook, developers have extensive access to user information, but it is often unclear if, when and how they exploit this data. This situation is perpetuated by Facebook’s unwillingness to regulate the widgets that operate on the site. As a result, users often have no idea who is collecting their data, how information is obtained as one interacts with these applications and how such data – even so- called not non-personally identifiable information – is subsequently used. By eschewing liability and placing the burden of responsibility on developers to police their own applications, Facebook unnecessarily exposes its users to cyber-threats like adware, malware and hackers. In many ways, Facebook has created a
dynamic social network, but because of the practices that it has adopted, it needlessly places the privacy and security of its users in harm’s way.”

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Brand Marketing and Social Media

Brand marketers, including movie studios, apparently love those “viral” applications to help drive ticket sales. We will have more to say about this topic soon, including at the FTC. At yesterday’s Social Media Business School “class,” the veterans from the digital ad business (meaning those somewhat over thirty) schooled the mostly in their twenties hungry developers about hitting the big time with the largest brand advertisers. The session I attended focused on the question: “What are Brands looking for in Social Advertising: eyeballs, interactions or engagement.”

I hope brands are also looking for corporate responsibility. There will be many–including my group–which do.

Can Social Media Find a Business Model That Protects Privacy?

It’s clear that many of those trying to monetize third-party applications are pushing the privacy envelope. For example, at yesterday’s “Social Media Business School” event in San Francisco, one panel on “Performance Advertising” discussed “[H]ow to turn clicks and leads and other forms of user response into cash.”

Social media leaders better change the ” P” in the acronym CPA (cost per action) to mean Privacy.