From: Jason Catlett catlett@junkbusters.com
Junkbusters Corp. is pleased to submit the attached rebuttal comments in response to the NTIA and FTC's public invitation to comment. These are posted at http://www.junkbusters.com/profiling.html Respectfully submitted Jason Catlett A Brief Critique of the Westin/Doubleclick survey At the NTIA/FTC hearings on online profiling a survey was presented by Privacy and American Business claiming that most consumers find ad targeting based on profiles acceptable. These conclusions are based on an untenable interpretation of the questions actually asked. Here are excerpts from the questions; the last one is key. Would you be willing to describe your interests if the company providing tailored ads spelled out how they would use your information, and you could "opt out" of uses you did not approve? By asking you to allow information about your VISITS TO web sites on the internet to be used to tailor Internet banner ads to you? Would you be willing to allow information about your VISITS to web sites on the Internet to be used if the company providing tailored ads spelled out how they would use your information, and you could "opt out" of uses you did not approve? If a company explains to you just what they want to collect and how they will use it, and if you can "opt out" of uses you did not approve, would the creation of a profile for presenting tailored banner ads be acceptable to you? The trick here is whether the survey respondent would consider an ad company that he or she has never heard of to have "explained" to him or her what they want to collect. No reasonable person would consider that the existence of a privacy policy page somewhere on a web site he or she had never heard of to meet the condition that "if a company explains to you just what they want to collect and how they will use it." Yet in the interpretation of the results the survey mischaracterises this as "notice." It also switches the context of the term "opt out" from specific uses where the consumer was volunteering information to a completely different situation where it is being collected without the consumer's knowledge. The hypothetical world that the survey respondent was asked to imagine when the survey was taken is preposterously remote from the one that the readers of the report would assume when considering conclusions such as this one:
The survey was sponsored by Doubleclick. CC: HQ.DCMAIL4(PROFILE) |