Submission to the U.S. Federal Trade Commission
Written by Dr Johnny Ryan of the Irish Council for Civil Liberties (ICCL) on behalf of ICCL, Open Markets Institute, and the Trans Atlantic Consumer Dialogue
21 November 2022 — ICCL, the Open Markets Institute, and the Trans Atlantic Consumer Dialogue, a forum of 75 NGOs, have sent the U.S. Federal Trade Commission (FTC) a joint submission (Link) on the privacy, market, and security hazards of surveillance advertising, urging the agency to act against commercial surveillance and to define “Real-Time Bidding” (RTB) as an unfair and deceptive practice.
The FTC is considering new privacy rules to protect Internet users against tracking. The ICCL/Open Markets/TACD submission lays out the harms of tracking-based online advertising and urges the FTC to develop rules that protect Internet users.
Surveillance advertising destroys individual privacy. Advertising’s “Real-Time Bidding” (RTB) system broadcasts Americans GPS coordinates and what they are doing online 107 trillion times a year. RTB is the dominant technology of online advertising, and triggers almost every time you load a page on a website, or use an app.
- This exposes people to significant risk with examples like predatory profiling of a suicidal gambling addict, county sheriffs buying live feeds of people’s locations, and data on victims of sexual abuse being made available to buy.
- Every year criminals exploit tracking-based advertising systems to steal billions of dollars from businesses who unknowingly pay to show ads to bots.
- Surveillance advertising also poses significant national security risks: Google and other RTB companies broadcast the locations of Americans – including sensitive personnel – to companies around the world including those in China and Russia.
The tracking industry tries to claim commercial surveillance has benefits beyond their own bottom lines; that it supports publishers or sustains the open Internet for regular people. Instead, tech companies have siphoned an estimated $35-$69 billion away from newspapers and other publishers and businesses.
ICCL Senior Fellow Dr Johnny Ryan wrote the submission. He said: “Surveillance based advertising hurts the internet and exposes us all to discrimination, manipulation, and to private and government surveillance. We urge the FTC to act to protect people”.
Finn Lützow-Holm Myrstad of the Norwegian Consumer Council, a TACD member organisation, said “This is also of key interest to European consumers, and this is why US and European groups are a issuing a joint call to action on a business model that we believe are at fundamental odds with fundamental rights“.