Facebook to America: We want to target your kids with ads, collect their data, violate their privacy [Annals of COPPA/FTC]

The same comedy writers at Facebook who wrote about the glories to be from its IPO--now a colossal joke--were just put to work again in the social ad network's new FTC comments on children's privacy (COPPA).  Like the hype used to blur the real financial prospects of Facebook, its arguments against strengthening rules to better protect children 12 and under from intrusive and manipulative digital data collection practices are based on a lack of candor.  Undoubtedly, Mark Zuckerberg and company will be peddling the Brooklyn Bridge for sale soon.

Facebook has a lot of problems with the FTC proposal--which has been backed by nearly all the leading child health, child welfare, consumer and privacy groups.  Facebook argues that it violates the First Amendment, among other complaints.  But how does Facebook start its anti-kids privacy screed?  By framing the issue as the need to provide children with access to more educational opportunities online.  When you read the first few pages, you would think Facebook is nothing but a high-minded library fostering digital learning--instead of the hyper-targeted social media marketer and data collector they really are.  Before Facebook makes its long-list of objections to kids privacy, it says that educational sites such as the Khan Academy will be harmed by new privacy safeguards.  Unfortunately, the folks at Facebook failed to see how the Khan Academy recognizes that kids privacy is a real concern, and it's perfectly able to offer various safeguards and tools for both kids and parents.   Facebook also claims it has a great track record protecting teens--instead of admitting it is one of the world's leading online sites targeting adolescents and other youth with powerful junk food ads (the folks at Facebook must have not heard about the world's obesity epidemic, inc. in the U.S.). 

Under the FTC's proposed rules, companies like Facebook that lure users to its platform through strategies such as the Like button would be responsible when they knowingly collect data from children and don't get parental consent.  The social network spins a fantasy tale about the real relationship of its Like button with other sites.  However, they failed to tell the FTC that the core of Facebook's business model is its "Open Graf" system--which is linked to its ad and social media marketing machine.  Facebook's strategy is to get its icon all over the place, so it can target users 24/7.  Indeed, Facebook is strangely silent about its recent dramatic expansion of user targeting both inside and outside Facebook, esp. via the Facebook Exchange.  We refer people to last week's letter to the FTC sent by CDD and EPIC on Facebook's data broker-based expansion, as well as our letter to several Judges involved in a class action suit Facebook is trying to settle over the unfair use of its "Sponsored Stories" ad system involving teens.

Facebook hates the idea that all the stealth data collection it, its many data targeting partners, and others use today would suddenly become under the control of a parent--who would be empowered to make informed decisions about their child's privacy practices.  Facebook doesn't want parents to know about its use of cookies and data-enabled social media marketing (read "viral" marketing on digital steroids) it uses.  They want to target kids and teens with interactive advertising of their own (so-called "first-party") and their partners--asking the FTC to exempt this practice despite the privacy and related risks. 

And Facebook's claims that it's Like button is "constitutionally protected speech" is a joke.  Facebook's business model uses stealth practices to get people to click and involve their friends--that's how its social media marketing works.  It's highly manipulative, non-transparent and often includes practices that are both unfair and deceptive.

The real objective here is that Facebook wants to go after kids.  The company is floundering because it hasn't made the sale on mobile devices.  Kids, along with teens, are the key users of mobile media--which is great for delivering data-enabled ads and marketing services.  Both Consumers Union and my CDD have already expressed grave concern about Facebook taking advantage of children.  Facebook isn't alone in complaining about COPPA--online marketers are terrified that these new rules will pry open hidden practices which are questionable and disturbing.  But Facebook's opposition to kids privacy online illustrates a corporate culture more interested in salvaging their share price that engaging responsibly with parents, consumer groups--and policymakers. 

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