A Preliminary FTC Staff Report on "Protecting Consumer Privacy in an Era of Rapid Change: A Proposed Framework for Businesses and Policymakers" #00031

Submission Number:
00031
Commenter:
Merriman
State:
Washington
Initiative Name:
A Preliminary FTC Staff Report on "Protecting Consumer Privacy in an Era of Rapid Change: A Proposed Framework for Businesses and Policymakers"

Device fingerprinting is apparently being moved to as a replacement for cookies as a means to track consumers. Cookies as persistent identifiers were bad enough. Do Not Track should be an option for all consumers regardless of the technology used. I'd even prefer opt in only tracking if it wasn't burried in the privacy policies as a condition of using a site. "It's tough even for sophisticated Web surfers to tell if their gear is being fingerprinted. Even if people modify their machines adding or deleting fonts, or updating software fingerprinters often can still recognize them. There's not yet a way for people to delete fingerprints that have been collected. In short, fingerprinting is largely invisible, tough to fend off and semi-permanent." "Blue Cava also is seeking to use a controversial technique of matching online data about people with catalogs of offline information about them, such as property records, motor-vehicle registrations, income estimates and other details. It works like this: An individual logs into a website using a name or e-mail address. The website shares those details with an offline-data company, which uses the email address or name to look up its files about the person. The data company then strips out the user's name and passes BlueCava information from offline databases. BlueCava then adds those personal details to its profile of that device. As a result, BlueCava expects to have extremely detailed profiles of devices that could be more useful to marketers. In its privacy policy, BlueCava says it plans to hang onto device data "for the foreseeable future." This combining of "off-line" data with a device profile is particularly troubling. The next step may be adding surfing habits to credit histories or other databases. The other problem is there is nowhere that a consumer can even see what these companies have accumulated about them nor a means of correcting the information. I don't mind display advertising. Web sites have to make money. I object to this kind of information gathering. Advertisers can do what they have previously done which is advertise on sites that attract likely prospects for their product or service. Please see attached WSJ report that contains the quoted information.