CDD to FTC: Google Violated Buzz Consent Decree by Failing to Inform Consumers Real Reasons for its Expanded Data Practices

The attached complaint was sent today to the FTC, including the following to the Secretary, Commissioners, and staff:

The Center for Digital Democracy submits this complaint regarding the failure of Google, Inc. to abide by the commission’s Consent Decree in the Google “Buzz” case (Docket No. C-4366). We respectfully urge the FTC to find Google in violation of the Consent Decree for its failure to accurately and honestly inform users the real reasons it is changing its privacy policy. This petition provides data and analysis showing how Google’s business practices, especially those announced or implemented in 2011, are the real reasons why it is now altering its consumer privacy practices. CDD also seeks to have the FTC request that Google postpone the launch of its new privacy policy on March 1, 2012, pending the outcome of its investigation.

Here’s an excerpt:

We believe that an analysis of Google’s business operations over the last year will demonstrate the true rationale for the changes to its privacy policy—which has nothing to do with making it “easier” or “more convenient” for users. We fail to see where Google has provided to users—as it claims to have done in its “Compliance Report” submitted to the commission—“clear information in order to exercise meaningful choice regarding their continued use of Google services….” In particular, Google fails to inform its users that the new privacy regime is based on its own business imperatives: to address competition from Facebook; to grow its capacity to finely profile and target through audience buying; to collect, integrate, and utilize a user’s information in order to expand its social media, social search, and mobile marketing activities (through YouTube, Google+, and Admob, for example); to extend the length of time during which users are subject to targeting and real-time auctions via its DoubleClick Ad Exchange and Display Network; to provide additional data points for its Teracent, Invite Media, and Admeld operations; and generally to expand its DoubleClick operations. Finally, Google should have explained to consumers what it told a private industry meeting—that to help fulfill its February 2011 prediction that display advertising will be a $200 billion dollar global industry, it would need to better integrate user data across platforms and application using digital ad marketing automation.