Who is Opposed to Protecting Kids Digital Privacy?--Toy, Advertising, and Direct Marketing Companies [Annals of COPPA]
We wish we could have Congress call in the leaders of the online ad lobby and, like they did with tobacco execs, have the executives swear they are telling the truth. Because what many of the companies and trade associations told the FTC in their comments on COPPA are full of false statements and purposeful misinformation.
Take, for example, the comment filed by the American Ass. of Ad Agencies, Assoc. of National Advertisers, Direct Market Assn., Interactive Ad Bureau, Toy Industry Association and US Chamber of Commerce. Just as many in the online ad industry originally claimed back in 1998 that COPPA would be burdensome and undermine the vitality of the Internet, they are once again echoing that same refrain. While these groups are content with COPPA today, they are alarmed that the proposed changes our coalition supports would "ultimately limit the interactivity and availability of online activities of children." Odd that despite the concerns expressed back in the late 1990's that COPPA would similiarly impact the kids online market, these groups say that with COPPA, "children generally have access to a rich variety of online offerings." Yet, their strange and self-serving logic poses, making COPPA more effective would somehow do to the kids market what hasn't happened yet. They also protest that parents would somehow be confronted with "multiple and lengthy" privacy notices. In another words, they don't want to be required to provide parents with the candid and accessible information they require. These companies and trade groups prefer to keep what they do, in terms of data tracking and targeting, a secretive process that is out of bounds for meaningful parental control.
The groups real concern is that they don't want to ensure that children's privacy is protected in the behavioral profiling and tracking era. They don't want the tools commonly used to target an individual today--IP addresses, cookies, web bugs, and other so-called persistent identifiers--to be more formally incoporated into the COPPA rules. They are fearful as well that parents will be given greater control of what happens to their child online, and that key safeguards requiring they not collect so much data on our children, be implemented. What these groups told the FTC is at odds with how online marketers do business online--where cookies and other identifers are the key to the individual user targeting system. It's individuals who are being targeted (and sold via exchanges)--that's what happens online. Yet they are telling the FTC the exact opposite of what they actually do and say to each other.
But the list of groups signing on here is telling. Toy companies and other online marketers want unfettered access to our children and their data--all for targeting. These companies and trade groups risk being exposed as purely concerned about collecting massive amounts of data on kids--and not interested at all in respecting their privacy and the interests of parents. Stay tuned for more in this series. The FTC will need to stand up for kids and parents--not with the data brokers.
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