Hearing #1 On Competition and Consumer Protection in the 21st Century - Sept. 13-14 at Georgetown University Law Center #FTC-2018-0074-D-0018

Submission Number:
FTC-2018-0074-D-0018
Commenter:
Chris Pedigo
Organization:
Digital Content Next
State:
District of Columbia
Initiative Name:
Hearing #1 On Competition and Consumer Protection in the 21st Century - Sept. 13-14 at Georgetown University Law Center
We applaud the FTC for moving forward with a series of hearings to examine Competition and Consumer Protection in the 21st Century. While the public has been focused on the ongoing Facebook and Cambridge Analytica scandal, Google has largely avoided public scrutiny about its data collection practices despite having the ability to collect far more personal data about consumers across a variety of touchpoints. There have been efforts to document individual practices by Google such as their efforts to circumvent controls on Safari. More recently, an investigation by the Associated Press revealed that Google continues to track location data even after a consumer has turned off the setting. While these research efforts have been important to the public policy dialogue, no research exists which looks at the breadth and depth of data collected by Google. To assist with the FTCs examination, we want to draw your attention to new research, entitled Google Data Collection, conducted Professor Douglas C. Schmidt, Professor of Computer Science at Vanderbilt University, has fully catalogued how much data Google is collecting about consumers and their most personal habits across all of its products and how that data is being tied together. The key findings include: A dormant, stationary Android phone (with the Chrome browser active in the background) communicated location information to Google 340 times during a 24-hour period, or at an average of 14 data communications per hour. In fact, location information constituted 35 percent of all the data samples sent to Google. For comparisons sake, a similar experiment found that on an iOS device with Safari but not Chrome, Google could not collect any appreciable data unless a user was interacting with the device. Moreover, an idle Android phone running the Chrome browser sends back to Google nearly fifty times as many data requests per hour as an idle iOS phone running Safari. An idle Android device communicates with Google nearly 10 times more frequently as an Apple device communicates with Apple servers. These results highlighted the fact that Android and Chrome platforms are critical vehicles for Googles data collection. Again, these experiments were done on stationary phones with no user interactions. If you actually use your phone the information collection increases with Google. Google has the ability to associate anonymous data collected through passive means with the personal information of the user. Google makes this association largely through advertising technologies, many of which Google controls. Advertising identifierswhich are purportedly user anonymous and collect activity data on apps and third-party webpage visitscan get associated with a users real Google identity through passing of device-level identification information to Google servers by an Android device. Likewise, the DoubleClick cookie IDwhich tracks a users activity on the third-party webpagesis another purportedly user anonymous identifier that Google can associate to a users Google account. It works when a user accesses a Google application in the same browser in which a third-party webpage was accessed previously. A major part of Googles data collection occurs while a user is not directly engaged with any of its products. The magnitude of such collection is significant, especially on Android mobile devices, arguably the most popular personal accessory now carried 24/7 by more than 2 billion people. DCN is grateful to support Professor Schmidt in distributing this research. We offer it to the public with the permission of Professor Schmidt. Chris Pedigo SVP, Government Affairs Digital Content Next