A Call to Analyze Online Advertising
In 1999, when the FTC held its online profiling workshop in 1999, there was almost an entirely different Internet advertising industry. At that time, the online advertising was rapidly becoming a mainstay of every Internet user's online experience, the industry was still in its infancy and the technologies being deployed were still undergoing rapid development. DoubleClick, the network advertising industry leader that was acquired by Google last Friday, was serving an average of 45 billion ads per month at that time - approximately one fourth of the number of ads that it serves today. Advertising volume is just one of the many ways that the landscape has changed. More and more consumers are making use of technologies such as Web search and Web-based email, with a corresponding increase in the collection and use of the associated data for marketing purposes. Profiling information is also being used across contexts - data collected on the Web might be used to target ads on television or radio, and databanks of information collected offline are being used to target online ads. Online video advertising and integration with Web 2.0 services are gaining increased attention as marketers tap into the ever-evolving multimedia online experience. The Network Advertising Inititive (NAI) agreement that was signed at that time is now completely out of date, to the point that it may not apply to any particular company today. In light of all these developments, CDT has been urging the FTC to revisit the privacy issues surrounding online profiling and behavioral targeting. Earlier this year, we wrote a letter to FTC Commissioner Thomas Rosch that outlined what an FTC workshop on these issues might look like. We believe the time is ripe for the FTC to drill down on current technologies, re-examine the self-regulatory landscape, and identify the Commission's own future course in relation to targeted advertising. Google's acquisition of DoubleClick shows exactly why an FTC workshop is needed. Google has traditionally focused on matching advertising to the context of a particular Web site, gathering mounds of data about how users interact with particular ads on individual sites. DoubleClick, on the other hand, specializes in gathering data across sites in an effort to help companies target rich media advertisements. Google, today, says that it has no plans to tie past history or search information across Web sites. Google says that it has no plans to match the DoubleClick cookies with any Google cookie. Yet, the possible integration of these two data sets - along with all of the other search data that Google collects - raises issues that the FTC could not have foreseen in 1999 and exemplifies the evolving privacy challenges in the online advertising space. It's time to deepen the dialogue about behavioral targeting, and an FTC workshop would be a great way to start.