In his comments to the FTC, Ari Levenfeld, senior director of privacy and inventory quality at Rocket Fuel and a board member at the Network Advertising Initiative (NAI), laid out what he sees as the advantages of cross-device.
“When done in a responsible and privacy-friendly way, cross-device identification is a reasonable and unobtrusive way to anonymously identify intended individuals and provide them with a useful marketing message,” Levenfeld wrote, noting that the consumer remains anonymous throughout the tracking and prediction process.
It was a sentiment echoed by the NAI’s director of policy, Jurgen Van Staden, at the workshop itself on Nov. 16: “One of the key benefits is the ability for marketers to provide consumers with a much better experience.”
But when Van Staden went on to observe that the “two biggest benefits” are actually the ability to help marketers and advertisers “better understand their audience and give publishers the ability to monetize their content in a new way,” Andrew Sudbury, the CTO of Abine, a company that develops online privacy tools, called him on it.
“It’s clear that first-party cross-device tracking could have benefits to consumers, but the rest of the benefits we’re discussing are not direct benefits to the actual users of devices,” Sudbury said. “You can make some trickle-down derivative argument that it’s useful to consumers, but I think the trade-off of what they’re giving up could be substantial.”
Van Staden countered with the classic value exchange argument: “Enjoying the content and all the services that we enjoy on the Internet for free is [not] a trivial argument.”
And therein lies the rub. Either the value exchange isn’t clear to consumers, or consumers aren’t interested in the terms.
Regardless, consumers and the online ad industry have trust issues, as evidenced by most of the comments that the FTC received from regular folks.
According to the Pew Research Center, 93% of US adults say it’s important for them to be in control of who can get information about them, and 90% feel it’s important to have control over what information is being collected. In stark contrast, 76% are either “not too confident" or “not at all confident” that “records of their activity maintained by the online advertisers who place ads on the websites they visit will remain private and secure.” Sixty-nine-percent of people felt the same lack of confidence in social media sites.
But do consumers care about their privacy in practice, not just in theory? It’s a difficult question to answer.
From one perspective, consumers seem to blithely give up personal data for access to free content and services – Facebook, Google, YouTube, online news.
For his part, Joseph Turow, a privacy researcher and professor of communications at the University of Pennsylvania, views the divergence between stated concern and actual behavior somewhat differently – as a sort of collective sigh in the face of confusion.
“The short of it is, people know they are being tracked, [but] at the same time, they don’t understand data mining, they don’t understand what goes on under the hood,” said Turow at the FTC’s workshop. “We have found that the more people knew about what goes on online, the more resigned they tended to be.”
In comments submitted to the FTC on Dec. 16, the Electronic Privacy Information Center (EPIC) summed up what it sees as the central problem: “Consumers lack meaningful control over this intrusive business practice.”
However, what EPIC sees as an intrusive business practice, the Interactive Advertising Bureau sees as bolstering “the benefits that consumers experience from interactive advertising by providing better access to content across devices.”
But Amy from Nebraska is simply “opposed to any tracking by any device I may use.” It’s a viewpoint utterly at cross-purposes with the way online advertising works.
Although Apple’s moral high ground isn’t as high as CEO Tim Cook would have us believe – an enormous number of apps in Apple’s App Store survive on advertising – what he said back in September 2014 remains true: “A few years ago, users of Internet services began to realize that when an online service is free, you’re not the customer. You’re the product."
As for the FTC’s plans following the cross-device workshop, Laura Riposo VanDruff, assistant director of the commission’s Division of Privacy and Identity Protection, told AdExchanger in November that the submitted comments, together with the information presented at the workshop itself, “will help inform what our next step may be.”
Although VanDruff was not more forthcoming than that, she did say, “The commission has long called on industry and applauded industry for their self-regulatory efforts.”