Last Friday, Yahoo! submitted comments on the Federal Trade Commission’s (FTC) recently distributed staff paper titled, Protecting Consumer Privacy in an Era of Rapid Change: A Proposed Framework for Business and Policymakers. We provided the FTC our thoughts and recommendations on the policy positions outlined in the staff paper as well as highlighted areas that need further consideration and evaluation by the FTC.
Privacy has been part of Yahoo!’s DNA since our founding. We have been at the forefront of protecting our users online for almost two decades and addressing privacy concerns is an issue that we have always taken seriously. We believe that our comprehensive approach to customization across a variety of platforms and our efforts to integrate privacy protections directly into our offerings help provide the best experiences for users in the new digital world, a world that exists beyond traditional geographic boundaries.
Privacy is an extremely complex issue with many dimensions and layers that are context and user specific. There is rarely a one size fits all approach because consumers have different attitudes and different preferences. What is critical is to offer transparency, privacy tools and education to consumers while still allowing businesses the flexibility to offer the kinds of products that consumers demand and to do so in a way that preserves the consumer benefits of free online content and services. Our comments highlight the complexity of the debate and the finer nuances of the issues at hand, particularly about concepts like Do Not Track and Privacy By Design.
‘Do Not Track’ (DNT) has been in the news and on the minds of legislators, media and online companies. In fact, the three major browser companies have recently introduced proposals for DNT. Simplified choice for consumers is the goal of DNT proposals and Yahoo! agrees with this objective. However, a key concern for online companies is that some DNT proposals eliminate the basic collection of user data; a scenario that creates barriers not only to routine Internet operations, but also to basic fraud detection and prevention processes.
Aside from browser provided controls, there are well-developed Web-based tools that offer strong protections that should not be ignored. The Digital Advertising Alliance’s Advertising Option Icon program is the strongest approach to DNT available today, and least likely to undermine the benefits of Online Behavioral Advertising, which the FTC indicates is also one of their goals for DNT. The Advertising Option Icon program already covers the vast majority of the advertising marketplace that uses behavioral targeting tools, and the implementation is growing in size and scope. In this program, ad markers take users to information and choices about advertising – an unprecedented effort to allow users to make choices on an industry-wide basis. As the program continues to roll out, additional educational efforts will help users better understand the meaning of the symbols they see in or around online ads. Yahoo! will be doing its part; we have displayed an advertising label and icon over one-trillion times on the Yahoo! networks of sites alone. Yahoo! believes this effort is a strong answer to calls for DNT through enforceable self-regulation and should be further encouraged by the FTC.
Our thoughts on the concept of Privacy by Design (PBD) are also outlined in our comments. PBD is illustrated by applying privacy considerations throughout the entire life cycle of technologies and procedures. We support this idea of PBD and consider it to already be a fundamental component of how our products and services are developed. Yahoo! considers the privacy of our users when innovating and providing online experiences, and we have always believed that PBD allows us to address privacy concerns when we build protections into the product architecture.
Consumer education remains at the heart of these issues, and is an important part of the privacy conversation as well. Many choices are available to consumers through Web tools, browser tools, and contextual features in existing products and services. Yahoo! helps empower consumers to use these simple to use and easy to access tools by making available additional supporting information – providing the education and background many users desire. These efforts are fundamental to our continuing efforts to build trust with our users.
Yahoo!’s full comments can be accessed at http://www.ftc.gov/os/comments/privacyreportframework/00444.html.
Anne Toth, Chief Trust Officer, Yahoo! Inc.
