Month: January 2010

What the new online ad industry-sponsored plan to identify Behavioral-Targeted Ads and Data Collection with the letter “i” really stands for: ineffective [And should be relabeled “ID”—Ineffective and Disingenuous]

Statement of Jeff Chester, executive director, Center for Digital Democracy, Washington, D.C. www.democraticmedia.org

A new self-regulatory scheme designed to head-off meaningful consumer privacy rules by Congress and the Federal Trade Commission is to be released today, according to several reports.  In addition, the Council of Better Business Bureaus has issued a RFP asking for technology solutions to bolster its online advertising self-regulatory approach.

These efforts are trying to place a flimsy band-aid over a gushing consumer data privacy wound.  Disclosure and more opportunities to opt-out is an online ad industry copout. Interactive marketers have created a data collection monster.  What’s needed are Fair Information Principles for the digital age, enforced by regulators, which dramatically minimize how much data is collected, stored, sold and resold–and limit how it can be used.   Instead we get fancy package relabeling fashioned by Madison Avenue.

Consumers face a bewildering, far-reaching, and complex system created by the online ad business that collects and harvests their information—including financial, health, and other personal details—that is non-transparent and unaccountable.  These new self-regulatory initiatives are disingenuous, because they don’t address the real problem:  that through a range of largely stealth online marketing techniques, digital media has been designed to ensure that consumers provide reams of their personal data.

As the FTC holds its second privacy hearing this Thursday, and as the House Commerce Committee finalizes its proposed legislation, policymakers must ask themselves:  how can we do a better job protecting consumers–instead of enabling the same kind of self-regulatory approach that helped bring our economy to the brink of disaster.  Consumers and lawmakers should especially be concerned that the approach backed by Truste and Future of Privacy Forum will permit monopolistic broadband Internet Service Providers, such as Comcast and AT&T,  to gather even more personal information on their subscribers.

Civil Liberties, Consumer & Privacy Groups to FCC: Protect Privacy


The American Civil Liberties Union, Center for Digital Democracy, Consumer Action, Consumer Federation of America, Consumer Watchdog, Privacy Lives, Privacy Rights Clearinghouse, Privacy Times, and U.S. PIRG told the FCC in a filing 22 January 2010 that: “There are significant problems concerning the collection and use of personal data by companies, especially sensitive data and children’s data; (2) The FCC should not rely on industry self-regulatory models because they do not adequately protect consumer privacy; and (3) The principles and standards that should serve as the foundation of consumer privacy protection should be the Fair Information Practices, especially as they are implemented in the OECD Guidelines on data privacy… The FCC should consider all avenues it may use to protect consumers, including exercising its ancillary jurisdiction to address broadband privacy issues, and working with Congress and the Federal Trade Commission (“FTC”), which has substantial expertise in consumer privacy protection.”


To learn more, click here.


Where Does Google and Microsoft Really Stand–with the IAB and ad lobby or for Consumer Protection?

Both Google and Microsoft serve on the executive committee of the Interactive Ad Bureau, a trade association fighting against consumer privacy proposals in Congress and the FTC.  The IAB just sent a letter signed by other ad and marketing industry lobbyists opposing Obama and congressional proposals to expand the ability of the FTC to better protect consumers.  My CDD just sent emails to officials at both Google and Microsoft asking them to clarify where they stand on the IAB’s letter [see below].  Do our two leading online marketing leaders support financial and regulatory reform, including protecting privacy?  Or does the IAB letter–and Google and Microsoft’s own role helping govern that trade lobby group–really reflect their own position against better consumer protection? Not coincidently, the IAB’s PAC has expanded its PAC contribution giving to congress.

Why does the IAB and other ad groups want to scuttle a more capable FTC?  Think online financial products, including mortgages, pharmaceutical operated social networks, digital ads targeting teens fueling the youth obesity crisis, ads created by brain research to influence our subconscious minds, a mobile marketing system that targets us because it knows our location, interests and behavior.  The IAB is terrified that a responsible consumer protection agency will not only peek under the ‘digital hood,’ as the Obama FTC is currently doing.  But actually propose policies and bring cases that rein in irresponsible and harmful business practices.  So Microsoft and Google:  who are with?  Consumers or the special interest advertising lobby?
*****

letter to Google:  22 January 2010

Dear Pablo, Jane, Peter and Alan:

As you may know, the Interactive Advertising Bureau recently sent a letter  to Congress, along with other ad related groups, opposing the expansion of FTC regulatory authority as proposed in the Consumer Financial Protection Agency bill and related reauthorization [http://www.clickz.com/3636212].

Google serves on the executive committee of the IAB’s board.  For the record, does Google support IAB’s stance that, as news reports say, if the FTC is given additional enforcement and penalty-making authority, “the FTC could essentially act as an unelected legislature governing industries and sectors across the economy.”

If Google disagrees with the IAB’s letter, I ask that it make its position public as soon as possible.  I also respectfully request Google state its position regarding the Consumer Financial Protection Agency proposal, as well as its position on expanding FTC authority.

Regards,

Jeff Chester
Center for Digital Democracy
www.democraticmedia.org

letter to Microsoft:  22 Jan. 2010:

Dear Mike and Frank:

As you may know, the Interactive Advertising Bureau recently sent a letter to Congress, along with other ad related groups, opposing the expansion of FTC regulatory authority as proposed in the Consumer Financial Protection Agency bill and related reauthorization [http://www.clickz.com/3636212].

Microsoft serves on the executive committee of the IAB’s board.  For the record, does Microsoft support IAB’s stance that, as news reports say, if the FTC is given additional enforcement and penalty-making authority, “the FTC could essentially act as an unelected legislature governing industries and sectors across the economy.”

If Microsoft disagrees with the IAB’s letter, I ask that it make its position public as soon as possible.  I also respectfully request Microsoft state its position regarding the Consumer Financial Protection Agency proposal, as well as its position on expanding FTC authority.

Regards,

Jeff Chester
Center for Digital Democracy
www.democraticmedia.org

Facebook Teams with JP Morgan Chase in Campaign Targeting Charities. But what about the bank’s role in the financial scandal?

As we have reported, banks and other financial institutions are using digital marketing techniques, especially social media, as part of their PR efforts.  Banks want to reposition themselves as our friend, and hope we will forget their role in helping bring us the greatest financial disaster since the Great Depression.  In it’s current voting contest for charities, “Chase Community Giving” will award $1 million to the charity getting the most votes (with $4 million doled out to others).  One of the advisors for this effort is Facebook’s exec in charge of its PR and lobbying Elliot Schrage.

Nothing said, of course, of Chase’s role in the economic crisis, including the bail-out funds it received [click here to see the Facebook/Chase video]. Meanwhile, Chase gets Facebook’s help, likely including lots of data on user behavior.

Facebook’s Ad “Targeting Specs”–including your “Political Views,” whether you are “13” years old, or “Engaged”

We continue to tell both the FTC and EU regulators that the data collected and used by Facebook for its ad targeting system must be under the control of its users.  Facebook is in the process of making its advertising API available to additional marketers (it’s been working with several large global ad agencies in a trial).  Here’s what Facebook says advertisers can target:  countries, cities, regions, genders, college networks, work networks, age minium [“Specify a minimum age to target. If used, this must be 13 or higher.”], age maximum, education status, college years, college majors, political views [“Use 1 for LIBERAL, 2 for MODERATE and 3 for CONSERVATIVE”], relationship status [“Use 1 for SINGLE, 2 for IN_RELATIONSHIP, 3 for MARRIED and 4 for ENGAGED.”], keywords [“Keywords are matched to user profile data to better target ads for example “movies” or “cars” can be used’], interested in, radius, connections [“Connections targeting allows you to target your ads to users who have become a fan of your Page, a member of your Group, RSVP’d to your Event or authorized your Application.”], excluded connections [“Excluded connections targeting allows you to target your ads to users who have not become fans of your Page, members of your Group, RSVP’d to your Event or authorized your Application.”], friends of connections [“An array of Facebook IDs. “Friends of connections” targeting allows you to target friends of your connections. Connections are fans of your Page, users who have RSVP’d Yes or Maybe to your Event, members of your Group, and users who have interacted with your Application.”], user event.

Google, Microsoft, China, Digital Advertising and Human Rights.

It took the equivalent of a Chinese digital Watergate break-in before Google reconsidered its position on China and their anti-democratic and censorious policies.  Google should never agreed to a censored version of itself in the first place.  But China represents what will be the world’s number one online marketing gold mine, irresistible for those in the interactive advertising business.  l hope that Google will actually withdraw from China, until democracy is assured.  But meanwhile, it’s interesting to briefly explore what Google and other online marketing companies are doing in the China market, including Hong Kong.

Google’s research division in China has been investigating “”Large-scale data mining and its applications for information retrieval.”  Google is still, as of today, listing job openings for its China operation. Google’s DoubleClick features its Hong Kong work (as part of its Asia Pacific focus).  [It’s also important to see what kind of data collection might be done by Google’s DoubleClick Ad Exchange in that market].

But policymakers and the public should also focus on Microsoft.  Microsoft has a key research lab on interactive ads based in Beijing; Microsoft Advertising has a major focus on China and online ads. Microsoft and many others research the online behaviors of Asians, including young users.  Yahoo operates in China as well. Finally, U.S. online ad companies focused on data mining are opening up branches in Hong Kong, in order to better position themselves with the Asia-Pacific market.

Google’s withdrawal from China would be a model for other companies–we hope it does it.  But the focus should be on how the online marketing industry at large, including ad giants such as WPP, are facilitating a system that deprives its citizens of their rights.

Facebook Boosts of its Brand Building Power, with Nielsen [“Brand Lift”] Research on the way to help

In a December 2009 interview in New Media Age, Facebook’s director for commercial marketing in the EMEA and UK market explained that [excerpt]:  CPMs on our home page are three or four times those of Yahoo’s. On click-through, the engagement levels we’re getting are 10-15 times that. Not 10% more, 10-15 times Yahoo’s click-through rates. This is where we’re selling to P&G and those big brands.  The other side of our business is performance: those little square boxes, ASUs [Ad Space Units], that appear everywhere except the home page. 80% of our inventory is driven through a self-service auction model. We’re on 50bn of them a month in the UK. That’s scale. And big brands are saying they’re getting more volume and lower cost than Google on Facebook right now…The big thing we’re bringing to the market in early Q1 is Nielsen-branded research, which will reveal what people are doing, using awareness consideration and favourability metrics that are important to branded advertising. We’ll be able to quantify this via Nielsen.“

Facebook to Graduate Students: Come help us data mine, boost online advertising, and we will pay your tuition

Facebook’s new academic Fellowship program places the social network along with other companies, such as Google, that like to tap into the “academy,” especially students.  Facebook says every day it “confronts among the most complex technical problems and we believe that close relationships with the academy will enable us to address many of these problems at a fundamental level and solve them.”   Among the areas Facebook wants inexpensive help with is “Data Mining and Machine Learning: learning algorithms, feature generation, and evaluation methods to produce effective online and offline models of behavioral signals.”  There are several other areas of interest, including “Internet Economics: auction theory and algorithmic game theory relevant to online advertising auctions.”

In exchange, Facebook offers to pay tuition, a $30k stipend, a travel allowance, and a chance for a paid summer internship.  The pitch must be endorsed by a faculty member that “clearly identifies the area of focus and applicability to Facebook.”   Our suggestion:  students should apply with projects which hold Facebook more accountable for its privacy and data collection practices.

Tracking Mobile Users by Behavior and Race: Why the FTC Must Address Mobile Privacy ASAP

Here’s a brief excerpt from the “The mobiThinking guide to mobile advertising networks 2010.”  Our emphasis.

Microsoft Mobile Advertising: Targeting capabilities include device, demographic (gender, age, household income), geographic and behavior.

Advertising.com/AOL: Full suite of targeting options, including device, browser, operating system, carrier, on/off-deck, geography, time-segment, content, and multiple demographic combinations.

Nokia Interactive Advertising: Demographics, location, handset type, and in the US by channels (e.g. auto, news, sports.

Quattro Wireless: a) contextual: media type, channel, publisher; b) demographic: gender, age, ethnicity, education; c) location; d) mobile: carrier, device class, manufacturer, model, features, operating system, browser; e) frequency of exposure.

Jumptap: Jumptap offers 64 different targeting options including: demographic, geographic location, carrier, on/off-deck (operator portal), device types and browser, time of day, day of week, content category and frequency controls. These targeting parameters are derived from multiple data courses, including contextual information and true carrier subscriber information. Premium brand advertising guarantees the ad will appear on certain sections of chosen site at the time specified.

Millennial Media: Audience targeting: Millennial can uniquely identify a user across all sites on the network – they are grouped into audiences, based on their observed behaviors on sites, participation and review of click-stream data, so campaigns can be targeted at specific audiences. (Millennial discloses these techniques, with an opt-out in accordance with the Self-Regulatory Principles for Online Behavioral Advertising, July 2009). Advertisers can also do Run of Network (RON) campaigns or target by channel, custom subnet, takeover, network blocks or demographic. There is also targeting via geography, carrier, handset model/manufacturer/operating system, handset features, age of device, time of day, location, Wi-Fi, etc.

Which “Network/Entertainment” Company is Expanding its use of Neuromarketing? NeuroFocus Looks for Specialist to help that showbiz client “Develop actionable insights from neurological studies”

Companies that rely on influencing brain behavior in order to achieve marketing goals are treading on a very slippery regulatory slope.  Nielsen-backed NeuroFocus is currently searching for a “Partner” in its “Consulting Practice.”  That person will be “responsible for the development and presentation of neurological studies commissioned by our key client in the network/entertainment industry…Of primary focus will be…developing insights from the neurological study results to benefit the client leading to a lasting relationship. Summary of essential job functions:

…
• Develop actionable insights from neurological studies
• Present results of neurological studies directly to clients
• Deep understanding of entertainment industry / network & cable television industry
• Experience in management consulting, market research, and advertising…

NeuroFocus, Inc. is the market leader in bringing neuroscience to the world of advertising, messaging, packaging, and product development. NeuroFocus clients include Fortune 100 companies across consumer package goods, food and beverage, entertainment, financial services, automotive, consumer electronics and retail sectors. NeuroFocus clients also include major companies in the TV and Motion Picture industries.”