January 26, 2022

Federal Trade Commission

Office of the Secretary

600 Pennsylvania Avenue NW

Washington, DC 20580

Re: Comment on Petition for Rulemaking by Accountable Tech, FTC-2021-0070 

INTRODUCTION

CDD joins 23 other public interest, consumer advocacy, and civil rights groups in a letter urging the Federal Trade Commission to protect civil rights and privacy in the digital economy by initiating a new rulemaking, creating an Office of Civil Rights, and committing more resources to enforce against unfair and deceptive practices.

The Center for Digital Democracy and 23 other leading civil society groups sent a letter to President Biden today asking his Administration to ensure that any new transatlantic data transfer deal is coupled with the enactment of U.S. laws that reform government surveillance practices and provide comprehensive privacy protections.

The coronavirus pandemic triggered a dramatic increase in online use. Children and teens whose schools have closed relied on YouTube for educational videos, attending virtual classes on Zoom and Google Classroom, and flocking to TikTok, Snapchat, and Instagram for entertainment and social interaction. This constant immersion in digital culture has exposed them to a steady flow of marketing for fast foods, soft drinks, and other unhealthy products, much of it under the radar of parents and teachers.

Contextual Advertising—Now Driven by AI and Machine Learning—Requires Regulatory Review for Privacy and Marketing Fairness

What’s known as contextual advertising is receiving a big boost from marketers and some policymakers, who claim that it provides a more privacy-friendly alternative to the dominant global surveillance-based “behavioral” marketing model. Google’s plans to eliminate cookies and other third-party trackers used for much of online ad delivery are also spurring greater interest in contextual marketing, which is being touted especially as safe for children.

General Comment submission
Children’s rights in relation to the digital environment

CONSUMER AND CITIZEN GROUPS CONTINUE TO HAVE SERIOUS CONCERNS ABOUT GOOGLE FITBIT TAKEOVER

Joint Statement on Possible Remedies

The Campaign for Commercial-Free Childhood (CCFC) and CDD filed comments with the UN’s Special Rapporteur on privacy, as part of a consultation designed to propose global safeguards for young people online.  Both CCFC and CDD, along with allies in the U.S. and throughout the world, are working to advance stronger international protections for young people, especially related to their privacy and the impacts that digital marketing has on their development.

The Center for Digital Democracy (CDD) announced today its opposition to the California Privacy Rights Act (CPRA), also known as Proposition 24, which will appear on the November 2020 California general election ballot. CDD has concluded that Prop 24 does not sufficiently strengthen Californians’ privacy and may, in fact, set a new, low, and thus dangerous standard for privacy protection in the U.S.