Proposed Consent Agreement In the Matter of Facebook, Inc., FTC File No. 0923184
I personally have been impacted by Facebook's deceptive business practices, as described in the FTC's eight-count complaint against Facebook from 2011. I had an active account with Facebook from at least 2004 until 2008. I decided to "delete" my account in 2006, but I was unable to do so because Facebook did not offer that option to any of its users at that time. After I contacted Facebook support to ask about deleting my account, I was told in an email message from "Christina from Facebook" on Wednesday, September 16, 2006 that in order to delete my account and all associated data from Facebook's servers, I would have to manually "delete everything." "Christina" elaborated: "This means you must delete all friends, photos, tagged photos, wall posts, messages, profile info, notes, etc. Once everything is gone I can finish the process from this end." This process would have required literally thousands of mouse clicks on hundreds of separate webpages, consuming probably 100 or more hours of my time. I began, but never finished, this unreasonably laborious process. Finally, over 18 months later, after privacy advocates pressured Facebook, in 2008 the company offered an automatic option to delete profiles and information. I took advantage of that option on February 13, 2008. In an email dated February 14, 2008, "Avery" from Facebook told me: "We have deleted your profile information and removed your email address from our login database." Today, however, I learned from the FTC complaint (Count 7) that my photos may still reside and remain accessible on Facebook's servers. I have no way of verifying whether my data is truly no longer in Facebook's possession. Given the blatant pattern of deceptive practices that have impacted myself and millions of other Americans, I believe that the FTC should not approve of any settlement against Facebook unless Facebook agrees to very frequent and comprehensive regulatory and oversight mechanisms. The biannual review proposed in the current settlement allows far too much flexibility and room for obfuscation in a fast-moving industry like internet social networking services. Facebook will introduce new products and services constantly, and the auditors in a biannual review will have too much to consider to effectively ensure that Facebook is complying with this agreement. Facebook should be required to submit to monthly audits, with a court-appointed auditor. Furthermore, Facebook should be fined for each violation in an amount proportional to the value of Facebook, rather than a set amount. Thank you for working on this important issue, and thank you for considering my comments.