|Secretary, Federal Trade Commission
600 Pennsylvania Avenue N.W.
Washington, D.C. 20580.
In February 1999, the Center for Democracy and Technology, joined by several others, filed a complaint at the FTC seeking immediate action to prevent harm to consumer privacy as a result of deployment of the Intel Pentium III Processor Serial Number (PSN). The complaint described the risks to consumers' privacy from the wide-spread deployment of a unique identifier for use across Internet interactions -- particularly one which was outside the control of the individual.
A central privacy concern surrounding the deployment of the Intel Pentium III Processor was its capacity to promote the tracking and profiling of individuals' online activities. We stated that the introduction of a persistent unique identifier for use across the World Wide Web would fundamentally change the Web experience from one where consumers can browse and seek out information anonymously, to one where an individual's every move is recorded. As we said at that time, our society's experience with unique identifiers suggests that embedding them into the structure of Internet interactions will erode individual privacy. Once a unique identifier capable of identifying and tracking individuals in the online environment is created, it will be far more difficult to limit its use.
In addition, in the complaint we stated that the PSN as designed by Intel was not adequately under the control of the consumer. Nor were there limits -- technical or legal -- on the purposes for which the PSN could be requested or used.
Shortly after we filed our complaint, we queried the major computer manufacturers asking how they would handle the privacy issue presented by Intel's latest chip. We were pleased to find that many manufacturers were concerned about the PSN's impact on privacy and decided to turn the PSN off.
While the PSN has not developed the way Intel assumed, its introduction represents a part of the larger issue surrounding identifiers and their relation to individual privacy. We welcome the FTC's commitment to explore this issue and seek the opportunity to participate in the upcoming Public Workshop on Online Profiling. We respectfully request to participate in Workshops II and III.