Submission Number: 00033
Received: 12/2/2010 10:42:28 AM
Commenter: Jake Winter
Agency: Federal Trade Commission
Initiative: A Preliminary FTC Staff Report on "Protecting Consumer Privacy in an Era of Rapid Change: A Proposed Framework for Businesses and Policymakers"
Attachments: No Attachments
I have great concern over this proposal. I work at a company in which my job is to track and analyze the behaviors of visitors to our website. As a direct result of my research and analysis, I make recommendations to improve the website and make it easier for our customers to use. Through this optimization, we can provide the best user experience possible for our customers.
It is this responsive feedback and optimization that has made the Internet the revolutionary communication tool it is today. The ability to quickly discern an entire population's frustration and pain points allows the Internet to be the most quickly reactive channel to ever exist. Other channels have to resort to representative samples that slow and restrict growth. That is exactly why the Internet has had the explosive growth and innovation in the past ten years. The tracking you are advocating to suppress is the cause for Internet becoming the burgeoning success it is. By demonizing and creating fear among Internet users, you are killing the exact innovations that spurred its growth. The work we do is not nefarious. It does not deal in personally identifiable information. It keeps everyone anonymous. It is not used in ways that take advantage of people's data. It is used to make the Internet a better tool for the people that use it. The shortcoming of this proposal is that it looks to evaluate all tracking equally. Yes, there are bad eggs out there that use behavioral tracking data for pursuits that are not ethical. Those should be dealt with on a case-by-case basis. A blanket condemnation of an otherwise beneficial industry would only stifle innovation and growth for the Internet as a whole. Not to mention kill jobs, like mine, in a recovering economy.
The failure of my industry is a lack of voice. We have not spoken loud enough or clear enough about what we track, and how we use it to better the Internet. Without the tracking we provide, Google and Facebook simply would not exist. The experiences that Internet users enjoy every day are enabled by the tracking of everyone's behavior. If that were undermined, innovation and growth would slow down as companies have to once again use representative samples of populations to optimize their products. This would slow down the ability for these companies to react and result in the Internet no longer being able to be the cutting edge for innovation.
Please take these comments into consideration as you move forward. And please, stop demonizing an industry and practice that has been overlooked and unappreciated since its creation.
Thank you for your time,