program areas Digital Citizen

Key control of multiple devices, including TV. ISPs have positioned themselves to expand their consumer data collection across all the devices/platforms they operate. This includes broadband connections (including streaming media), mobile devices, PCs, and also TV. Unlike Google and Facebook, the cable and telephone ISPs largely control the TV set. Comcast has enabled its NBC division to use its set-top (link is external) box data for targeting, for example. Phone and cable companies work with leading data brokers and data marketing “clouds” in order to develop granular and actionable profiles of individuals. This gives ISPs robust understanding of the actions and behaviors of consumers, including financial, health, ethnic, racial, shopping, and even politically related data—all of which is used for personalized targeted marketing. Examples include Comcast (link is external) and Verizon working with Acxiom, among others; Comcast (link is external) and Verizon working with real-time data targeting company MediaMath; Verizon and Comcast (link is external) working with Oracle’s (link is external) marketing cloud division; and Experian (link is external) providing data to Verizon/AOL and AT&T (link is external). ISPs are Identifying and targeting a single consumer across all the devices that person uses—through “cross device identification.” Verizon (which operates both AOL and Yahoo) works with Acxiom’s LiveRamp division. LiveRamp specializes in helping clients fuse together data that allows specific individuals to be identified (link is external) on all their devices, through LiveRamp’s “IdentityLink” LiveRamp matches “PII-based data—like emails, postal addresses, and phone numbers—with…cookies and device IDs….” The company maintains “consistent recognition on 98% of U.S. adults and nearly 100% of U.S. households.” Verizon’s Precision Insights Program is listed as a LiveRamp partner (“the two companies are leveraging the PrecisionID” to give advertisers the ability to run “list-matching” campaigns in mobile, and serve mobile ads to an already built CRM list). AT&T also has a connection with LiveRamp, via its alliance (link is external) for app-based data targeting with Opera Mediaworks. The list of LiveRamp’s data partners is far-reaching, suggesting that Verizon, for example, can acquire extensive data elements on individuals. AT&T has also worked with cross-device targeting specialist Tapad. (link is external) Verizon works with another cross-device company—Drawbridge (link is external)—which also has multiple data-broker partnerships. Phone and cable companies are using set-top box data to also target consumers on their other devices. For example, AT&T recently boasted, “we are now targeting that same consumer across TV and mobile.” ISPs are expanding their use of consumer geolocation data for commercial tracking and ad targeting, creating new privacy threats to neighborhoods and communities. For example, leading geo-tracking company Factual (link is external) is a partner (link is external) with Verizon’s AOL. AT&T (link is external) and Verizon (link is external) also work with geotargeter PlaceIQ. ISPs have been on a data-targeting spending spree to acquire companies that help them target across devices and applications. AT&T has partnered with ad- (and now also data-) giant WPP to own (link is external) a company that helps deliver digital TV and other interactive ads across devices. They are using “verified subscriber identities” to deliver addressable TV and mobile ads, including through apps. Verizon’s acquisition of Yahoo (including Yahoo Finance and Yahoo Mail) gave it control of over 600 million mobile monthly users. Yahoo mail has “225 million logged-in users,” for example, lending valuable scale to AOL’s (link is external) ad-platform business. “Verizon’s subscriber data coupled with Yahoo content and email addresses enables more precise ad targeting,” explained (link is external) one leading publication. ISPs are using their data clout to deliver insight-based targeting. Verizon, for example, promises that it “allows advertisers to pinpoint very specific targets by households." ---

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Deep Root Analytics, a leading media & audience analytics company that creates data platforms for audience targeting and ad monitoring, announced today that it has expanded the number of audiences available with D2 Media Sales to enable political, corporate & advocacy advertisers to target Dish and DIRECTV households using proprietary audience segments. Deep Root Analytics has created 35 new proprietary audience segments based on their affinity scores on political & policy issues and interest in corporate responsibility efforts. These new audiences represent an increase in the Deep Root Analytics footprint to reach Dish & DIRECTV households above their initial announcement (link is external) in 2016 and brings its overall addressable audience offering to more than 60 unique audience segments. As such, Deep Root Analytics has pre-matched these segments to D2’s advertising platform, providing addressable TV advertising to nearly 23 million DIRECTV and DISH satellite households. “In 2017, advocacy and brand advertisers are navigating a tricky and fractured media landscape. They are especially keen to identify and efficiently reach audiences based on what they value and to drive their agenda and manage their brand reputations,” noted Deep Root Analytics CEO Brent McGoldrick. “At Deep Root Analytics, we are focused on helping them make their paid media as data-driven as possible. So, we are thrilled to work with D2 Media Sales and access their best-in-class addressable TV platform to enable our clients to directly communicate with nearly 23 million DIRECTV & DISH customers.” The 35 new proprietary segments created by Deep Root Analytics and made available for addressable advertising via D2 Media Sales include: --- For more information, visit http://bit.ly/2ep1l0U (link is external)

Political data firms on both sides of the aisle have bolstered their addressable TV capabilities. Today, Democratic data firm TargetSmart and Republican data outfit Data Trust each announced new partnerships with TV data providers. The outcome should be even more TV spots, especially from congressional campaigns, targeted to households of key voter segments than ever before. Data Trust, the data firm that manages a national voter file for Republicans and right-leaning groups, has partnered with FourthWall Media to match FourthWall's cable viewership data to Data Trust's voter data. The result will be a feed of TV viewer data updated daily and matched against Data Trust's voting history and demographic data. It was a year ago at the Democratic National Committee's summer meeting in Minneapolis when Democratic data firm TargetSmart Communications unveiled the addressable TV and digital ad targeting capabilities it developed with data services firm Experian. Today, TargetSmart expanded its TV data offerings through a partnership with Tru Optik, which provides media consumption data for digital media and connected TV devices such as Roku, Xbox, and smart TVs. The company also has TV data deals with Rentrak and D2 Media Sales, which is a partnership between DISH and DirecTV/AT&T. "We're trying to get as many partnerships out there as possible," said Bill Russell, director of digital partnerships at TargetSmart. These sorts of voter and TV data deals are bringing the targeting capabilities of online advertising to TV ad buys, which historically have resulted in some wasted spending for political campaigns that would do better to target ads to desired voter groups rather than those less likely to support their candidates. The new approaches have grown in popularity following the 2012 election, when President Obama's re-election campaign famously employed innovative data-crunching methods for buying TV ads aimed at voters through programming rarely purchased by political advertisers. By partnering with more and more TV data and media firms, political data companies are bringing what was once accessible only to large statewide or national campaigns to smaller, down-ballot candidates. Through such relationships, political advertisers can reach pre-defined voter segments, such as likely Democratic or Republican voters, or custom groups of voters. --- For the full article, visit http://bit.ly/2wDaz4s (link is external)

The Center for Digital Democracy (CDD), a leading US NGO specializing in consumer data protection issues in the digital marketplace, is pleased to respond to the request that we provide information applicable to first annual review of the EUUS Privacy Shield. CDD has been assessing the Privacy Shield since it came into force in 2016, in part as a result of its work coordinating the activities from the US side of the Transatlantic Consumer Dialogue (TACD) working group on the Information Society. EU citizens and consumers who deal with companies enrolled in the Privacy Shield program confront a serious erosion of their data protection and privacy rights. The rights of EU citizens under the Privacy Shield program are not equivalent to how they would be protected by EU law. We urge the Commission and EU Data Protection Authorities to suspend the Privacy Shield in light of its lack of any policies, rules, or enforcement that would provide meaningful adequacy or equivalency. The Commission should insist that U.S. companies targeting EU citizens or consumers must operate under the forthcoming General Data Protection Regulation (GDPR) framework. For this submission, we reviewed the activities of several major U.S. companies enrolled in the Privacy Shield program, examining their submissions on the U.S. Commerce Department website (including descriptions of their activities, the link to and content of their privacy policy statements). We compared these statements to the actual data collection and use-related activities conducted by the companies, including their own descriptions of how they operationalize their business goals. We supplemented this analysis with the information that CDD extensively gathers on the commercial digital marketplace, such as automated “programmatic” decision making and other contemporary consumer-directed applications. --- For the full PDF of the letter, see attachment in link below.

Public Knowledge joined by the Consumer Federation of America, the Center For Digital Democracy, Consumer Action, Consumer Federation of California, and the Privacy Rights Clearinghouse writes a letter urging the Federal Trade Commission Acting Chairman, Maureen Ohlhausen, to protect consumer privacy. The letter is asking the FTC Chairwoman to publicly and expeditiously resolve a pending complaint concerning cable TV and satellite TV privacy. --- June 12, 2017 Maureen Ohlhausen Acting Chairman Federal Trade Commission 600 Pennsylvania Avenue, NW Washington, DC 20580 Dear Acting Chairman Ohlhausen: The Federal Trade Commission (FTC) has long protected consumer privacy, in tandem with other agencies, and you recently reiterated your dedication to protecting consumer privacy in the digital age through FTC enforcement. We therefore urge the FTC to quickly resolve the complaint filed one year ago by a coalition of consumer advocates. The complaint provides evidence that the nation’s cable and satellite providers have and continue to deceive consumers about their privacy practices by failing to provide adequate notice, in violation of Section 5 of the FTC Act. Since the complaint was filed, leading Internet Service Providers, cable and telephone companies have significantly expanded their ability to gather, analyze and make actionable data that is used to target subscribers, their families, and other consumers. --- See the link below for the full PDF of the complaint.

The new report by Cracked Labs titled "Corporate Surveillance in Everyday Life" with contributions by CDD's Katharina Kopp, provides a powerful overview of the commercial surveillance infastructure, key players and trends. The report is available as a ten-part overview online (link is external) and as a free, detailed 93-page PDF (link is external).

Facebook should immediately release all documents describing how it collected and analyzed psychological information it recently (link is external) collected about its youngest users, some as young as 14, and college students, Public Citizen and a coalition of 25 groups said in a letter (link is external) to the corporation today. The groups are concerned about how this information might have been used or may be used in the future by marketers and others to take advantage of young people’s emotions, all without users’ knowledge. Marketing companies and Facebook have secretly moved to tap into teens’ emotions and developmental vulnerabilities strictly for profit, the letter says. The groups want to know how the data was used, when it was used, how many users were impacted and the names of the companies that received the data. “What began as a way for college students to keep in touch has morphed into a platform for brand-saturated marketing and psychological manipulation,” said Kristen Strader, campaign coordinator for Public Citizen’s Commercial Alert campaign. “It is incumbent upon Facebook as a cultural leader to protect, not exploit, the privacy of young people, especially when their vulnerable emotions are involved.” According to The Australian (link is external) newspaper, Facebook presented research to one of its advertisers that shows it collects sensitive data regarding young users’ emotions and “mood shifts.” The research detailed how Facebook can analyze sensitive user data in real time to determine how young users are communicating emotion, and at which points during the week they are doing so, the letter continued. Facebook’s research was conducted without users’ knowledge, which raises ethical concerns. “Because Facebook plays such a powerful role in the lives of teens, it must adopt a policy that respects and protects them,” said Dr. Kathryn Montgomery, professor of communication at American University and a consultant to the Center for Digital Democracy. “This should include not only strong safeguards for its advertising and data practices, but also clear limits on the kinds of research it conducts for marketing purposes. Under no circumstances should marketers be using emotional states, stress levels, biometric information or other highly sensitive data to target users. And this should apply to both young people and adults.” “Facebook needs to come clean and publicly release the full internal document, reported in The Australian, describing how Facebook collected and analyzed psychological information on high school students, college students and young users, said Finn Lützow-Holm Myrstad, European Union co-chair of the Transatlantic Consumer Dialogue. “The burden of proof is on Facebook to document publicly that they don’t collect and use such information. We are concerned that companies don’t overreach and abuse their users’ fundamental right to privacy and data protection.” The public, its users and elected officials have a right to know how pervasive this research was, who was affected and how the company will ensure it does not occur again, the groups said. The only way to fully address those concerns is to publicly release the internal document and related materials, accompanied by a more detailed explanation from Facebook of what was intended, what happened and the company’s actual practices, the letter says. —30— --- See full PDF of letter to Facebook below.