Consumer & Privacy Coalition Ask FTC to Force Facebook to Comply with Consent Decree/Roll Back Proposed Changes that Threaten User Privacy, inc for Teens

The coalition's letter is attached.  Facebook is violating the terms and spirit of its 2011 Consent Decree with the Federal Trade Commission (FTC).  
 
As we have explained to FTC officials, the new policies planned by Facebook are designed to further expand its wide-ranging data collection and targeting apparatus.  Facebook must be required to be candid and specific to its U.S. users on how its new data use policies reflect what it sells to marketers and advertisers (its various ad products, data techniques, focus on mobile, etc.).  Without such candor and transparency,  Facebook is fundamentally in violation of the 20-year committment it made to the American public via the FTC.  The FTC has to stand up for the rights of U.S. consumers and make the Consent Decree--which the agency has repeatedly said has created new privacy safeguards for Internet users around the world--mean something.  The agency has claimed that its Facebook order "alone protects the privacy of more than a billion people world-wide."  That has largely been a fiction--something anyone who follows Facebook (as we do at CDD) know.  It's time for the FTC to take Facebook to court for violating its agreement.
 
Facebook's new policy on its 13-17 year old users is especially alarming.  It wants to target teens with an aggressive mix of data collection, profiling and tracking--without any safeguards.Here's what CDD's attorney Hudson Kingston said to us about Facebook's new tactic on teens:  "Across the United States, states' laws don't allow minors to definitively bind themselves with a contract. Through legal fictions Facebook's new policy tries to bind both minors and their parents to consent to ongoing invasions of privacy, based only on the nonaction of teenage users. This violates the FTC 2011 Facebook Order's requirement of affirmative consent before the company undercuts privacy, as well as basic concepts of capacity to consent."
 
Joy Spencer, who runs CDD's project on digital food marketing and youth, said:  "Teens spend their lives online 24/7, especially on social media platforms like Facebook.  They use Facebook to socialize and share critical information that often spreads quickly and has great power and influence within tight and trusted social networks.  By changing its Statement of Rights and Responsibilities and Data Use Policy to grant itself permission to use the name, profile picture, content and other actions of teen users for commercial purposes and without their express consent or compensation, Facebook is definitely stepping over the line.  Most teens do not share their personal photos and personal views on Facebook with the expectation that brands can take their pick of their images and actions to digitally market commercial products.  What is most disturbing here is that Facebook is taking advantage of teens while they socialize with peers and exploiting their rightful need for self-expression in order to make a profit.  The FTC should definitely step in to make sure this does not happen. "
 
Facebook's redlined changes is attached in the FBSRS document. Here's what it says (my bold):
 
10. About Advertisements and Other Commercial Content Served or Enhanced by Facebook
Our goal is to deliver advertisings and other commercial or sponsored content that are is valuable to our users and advertisers. In order to help us do that, you agree to the following:
1. You can use your privacy settings to limit how your name and profile picture may be associated with commercial, sponsored, or related content (such as a brand you like) served or enhanced by us. You give us permission to use your name, and profile picture, content, and information in connection with commercial, sponsored, or relatedthat content (such as a brand you like) served or enhanced by us, subject to the limits you place. This means, for example, that you permit a business or other entity to pay us to display your name and/or profile picture with your content or information, without any compensation to you. If you have selected a specific audience for your content or information, we will respect your choice when we use it.

If you are under the age of eighteen (18), or under any other applicable age of majority, you represent that at least one of your parents or legal guardians has also agreed to the terms of this section (and the use of your name, profile picture, content, and information) on your behalf.

AttachmentSize
Privacy Grps ltr to FTC 9-13 2.pdf164.26 KB
FBSRS-1.pdf257.87 KB