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Most parents can tell you the most popular website for kids is YouTube. But for years, while Google made millions luring children to YouTube, vacuuming up their sensitive information, and using it to target them with ads, Google told the Big Lie: “YouTube is not for kids. It says so right in our terms of service.” That has now changed, thanks to the advocacy of Campaign for a Commercial-Free Childhood (CCFC) and the Center for Digital Democracy (CDD) and the support of a coalition of advocacy groups. Google deliberately developed YouTube as the leading site for children with programming and marketing strategies designed to appeal directly to kids. But it ignored the only federal law addressing commercial privacy online—the Children’s Online Privacy Protection Act (COPPA). Their behavior sent a message that a corporation as powerful and well-connected corporation as Google is above the law—even laws designed to protect young people. CCFC, CDD, and our attorneys at the Institute for Public Representation (link is external) (IPR) at Georgetown University Law Center, with a broad coalition of consumer, privacy, public health and child rights groups, began filing complaints at the Federal Trade Commission (FTC) in 2015 concerning Google’s child-directed practices on YouTube and the YouTube Kids app. We kept up the pressure on the FTC, with the help of Congress and the news media. After we filed a complaint (link is external) in April 2018 describing YouTube’s ongoing violations of COPPA, the FTC, under the leadership of Chairman Joe Simons, finally decided to take action. The result was the FTC’s September decision (link is external)—which in many ways is both historic and a major step in the direction of protecting children online. Google was fined $170 million for its violations of children’s privacy, a record amount for a COPPA-connected financial sanction. The FTC’s action also implemented important new policies (link is external) protecting children, most of which will go into effect by January 2020: Children will no longer be targeted with data-driven marketing and advertising on YouTube programming targeted to kids: This is the most important safeguard. Google will no longer conduct personalized “behavioral” marketing on YouTube programming that targets children. In other words, they will stop the insidious practice of using kids’ sensitive information in order to target them with ads tailored for their eyes. Google will require video producers and distributors to self-identify that their content is aimed at kids; and will also employ its own technology to identify videos that target young audiences. Google will substantially curtail the data they collect from children watching YouTube videos. Since the main YouTube site has no age gate, they will limit data collection and tracking of viewers’ identities for anyone watching child-directed content there to only the data “needed to support the operation of the service.”. The same limitation will apply to videos on YouTube Kids. Google is taking steps to drive kids from the main YouTube site to YouTube Kids, where parental consent is required. Google launched the YouTube Kids app in 2015. But the app never rivaled the main YouTube platform’s hold on children, and was plagued with a number of problems, such as inadequate screening of harmful content. As a result of the FTC investigation, Google has launched a YouTube Kids website, and when kids watch children’s content on the main YouTube site they get a pop-up suggesting they visit YouTube Kids. Google says it will more effectively curate different programming that will appeal to kids aged 4 through 12. This is a positive development because, while a number of concerns remain about YouTube Kids, children are better off using the Kids site rather than the Wild West of the main YouTube platform. Google created a $100 million fund for “quality kids, family and educational content.” CCFC and CDD had proposed this, and we are gratified Google acknowledged it bears responsibility to support programing that enriches the lives of children. This is to be a three-year program to spur “the creation of thoughtful, original children’s content.” Google has made changes to make YouTube a “safer platform for children:” The company is proactively promoting “quality” children’s programming on YouTube by revising the algorithm used to make recommendations. It is also not permitting comments and notifications on child-directed content. Google has told CCFC and CDD it will make these changes regarding data collection and targeted marketing worldwide. Other questions remain to be answered. How will it treat programming classified as “family viewing”—exempt it from the new data targeting safeguards? (It should not be permitted to do so.) Will the new $100 million production fund commit to supporting child-directed non-commercial content (instead of serving as a venture for Google to expand its marketing to kids)? Will Google ensure that its other child-directed commercial activities—such as its Play Store—also reflect the new safeguards the company has adopted for YouTube? Google also permits the targeting of young people via “influencers,” including videos where toys and other products are unboxed. When such videos are child-directed, Google should put an end to them. CCFC, CDD and our allies intend to play a proactive role holding Google, its programmers, advertisers and the FTC accountable to make sure that these new policies are implemented effectively. Our work in bringing about this change and the work we will do to make other companies follow suit is part of our commitment to ensuring that young people around the world grow up in a media environment that respects and promotes their health, privacy, and well-being.

The Center for Digital Democracy provides the following recommendations for comprehensive baseline Federal privacy legislation. We are building on our expertise addressing digital marketplace developments for more than two decades, including work leading to the enactment of the 1998 Children’s Online Privacy Protection Act--the only federal online privacy law in the United States. Our recommendations are also informed by our long-standing trans-Atlantic work with consumer and privacy advocates in Europe, as well as the General Data Protection Regulation. We are alarmed by the increasingly intrusive and pervasive nature of commercial surveillance, which has the effect of controlling consumers’ and citizens’ behaviors, thoughts, and attitudes, and which sorts and tracks us as “winners” and “losers.” Today’s commercial practices have grown over the past decades unencumbered by regulatory constraints, and increasingly threaten the American ideals of self-determination, fairness, justice and equal opportunity. It is now time to address these developments: to grant basic rights to individuals and groups regarding data about them and how those data are used; to put limits on certain commercial data practices; and to strengthen our government to step in and protect our individual and common interests vis-à-vis powerful commercial entities. We call on legislators to consider the following principles: 1. Privacy protections should be broad: Set the scope of baseline legislation broadly and do not preempt stronger legislation Pervasive commercial surveillance practices know no limits, so legislation aiming to curtail negative practices should - address the full digital data life-cycle (collection, use, sharing, storage, on- and off-line) and cover all private entities’ public and private data processing, including nonprofits; - include all data derived from individuals, including personal information, inferred information, as well as aggregate and de-identified data; - apply all Fair Information Practice Principles (FIPPs) as a comprehensive baseline, including the principles of collection and use limitation, purpose specification, access and correction rights, accountability, data quality, and confidentiality/security; and require fairness in all data practices. - allow existing stronger federal legislation to prevail and let states continue to advance innovative legislation. 2. Individual privacy should be safeguarded: Give individuals rights to control the information about them - Building on FIPPs, individuals ought to have basic rights, including the right to + transparency and explanation + access + object and restrict + use privacy-enhancing technologies, including encryption + redress and compensation 3. Equitable, fair and just uses of data should be advanced: Place limits on certain data uses and safeguard equitable, fair and just outcomes Relying on “privacy self-management”—with the burden of responsibility placed solely on individuals alone to advance and protect their autonomy and self-determination—is not sufficient. Without one’s knowledge or participation, classifying and predictive data analytics may still draw inferences about individuals, resulting in injurious privacy violations—even if those harms are not immediately apparent. Importantly, these covert practices may result in pernicious forms of profiling and discrimination, harmful not just to the individual, but to groups and communities, particularly those with already diminished life chances, and society at large. Certain data practices may also unfairly influence the behavior of online users, such as children. Legislation should therefore address the impact of data practices and the distribution of harm by - placing limits on collecting, using and sharing sensitive personal information (such as data about ethnic or racial origin, political opinions/union membership, data concerning health, sex life or sexual orientation, genetic data, or biometric data) or data that reveals sensitive personal information, especially when using these data for profiling; - otherwise limiting the use of consumer scoring and other data practices, including in advertising, that have the effect of disproportionally and negatively affecting people’s life chances, related to, for example, housing, employment, finance, education, health and healthcare; - placing limits on manipulative marketing practices; - requiring particular safeguards when processing data relating to children and teens, especially with regard to marketing and profiling. 4. Privacy legislation should bring about real changes in corporate practices: Set limits and legal obligations for those managing data and require accountability Currently companies face very few limitations regarding their data practices. The presumption of “anything goes” has to end. Legislation should ensure that entities collecting, using, sharing data - can only do so for specific and appropriate purposes defined in advance, and subject to rules established by law and informed by data subjects’ freely given, specific, informed and unambiguous consent; for the execution of a contract, or as required by law; and without “pay-for-privacy provisions” or “take-it-or leave it” terms of service. - notify users in a timely fashion of data transfers and data breaches, and make consumers whole after a privacy violation or data breach; - cannot limit consumers’ right to redress with arbitration clauses; - are transparent and accountable, and adopt technical and organizational measures, including + provide for transparency, especially algorithmic transparency, + conduct impact assessments for high-risk processing considering the impact on individuals, groups, communities and society at large, + implement Privacy by Design and by Default, + assign resources and staff, including a Data Protection Officer, + implement appropriate oversight over third-party service providers/data processors, + conduct regular audits - are only allowed to transfer data to other countries/international organizations with essentially equivalent data protections in place. 5. Privacy protection should be consequential and aim to level the playing field: Give government at all levels significant and meaningful enforcement authority to protect privacy interests and give individuals legal remedies Without independent and flexible rulemaking data-protection authority, the Federal Trade Commission has been an ineffective agency for data protection. An agency with expertise and resources is needed to enforce company obligations. Ongoing research is required to anticipate and prepare for additionally warranted interventions to ensure a fair marketplace and a public sphere that strengthens our democratic institutions. Legislation should provide - for a strong, dedicated privacy agency with adequate resources, rulemaking authority and the ability to sanction non-compliance with meaningful penalties; - for independent authority for State Attorneys General; - for statutory damages and a private right of action; - for the federal agency to establish an office of technology impact assessment that would consider privacy, ethical, social, political, and economic impacts of high-risk data processing and other technologies; it would oversee and advise companies on their impact-assessment obligations.

A digital “great awakening” has occurred with unprecedented global attention given to the commercial surveillance (link is external) business model at the core of our collective digital experience. Since the earliest days of the commercial Internet in the 1990s, the online medium has been deliberately shaped (link is external) to primarily serve the interests of marketing. Advertisers have poured in many billions of dollars since then to make sure that our platforms, applications and devices all serve the primary need of gathering our information so it could be used for data-driven marketing. Internet industry trade groups have developed the technical standards (link is external) so that data collection is embedded in new services—such as mobile geo-location applications. Marketers developed new technologies, such as programmatic (link is external) advertising, that enabled lightning-fast decisions about individuals based on their data. Leading ad platforms, especially Google and Facebook, fought against privacy legislation for the U.S. Policymakers from both major parties protected them from regulation, including on privacy and antitrust. U.S. companies tried to derail (link is external) the new EU privacy law that starts on May 24—known as the General Data Protection Regulation (GDPR)—but failed to stop it. Europeans—who understand the threat to personal and political freedom when unaccountable institutions control our information—are now on the privacy front lines. The road to privacy and digital rights for America is likely first to pass through the European (link is external) Union. The Facebook/Cambridge Analytica scandal (and kudos (link is external) to The Observer newspaper for its dogged journalism on all this) is, however, not unique. It is emblematic of the way that digital marketing works every day—all over the world. Huge amounts of our information is scooped (link is external) up, from scores of sources, quickly analyzed, and used to send us more personalized marketing and content. Powerful automated (link is external) applications help marketers identify who we and then engage us at deeper emotional and subconscious (link is external) levels. Facebook, Google and others are continually pushing the boundaries of digital advertising, deploying Artificial Intelligence, Virtual Reality (link is external), Neuromarketing and other techniques. They are laying the foundation for the “Internet of Things” world that will be soon upon us, where we will be further tracked and targeted wherever we go and whatever we do. But it’s the global “Fortune” type companies that will really decide what happens with the online privacy of people all over the world. Google and Facebook basically work for the P&Gs (link is external), Coca-Cola’s (link is external), Honda’s and Bank America’s—the leading advertisers. It’s the advertisers who are really in charge of the Internet, and they have created (link is external) for their own companies a kind of mirror image (link is external) to what Google and Facebook have helped unleash. Fortune-size companies are now also in the data business, (link is external) collecting information on consumers via all their devices; they have created in-house consumer data mining and targeting services; and they deploy advanced digital marketing techniques to directly reach us. Over the last year, major advertisers have forced Facebook (link is external) and Google (link is external) to become more accountable to their needs and interests—rather than to the public interest. What they call the need for “brand safety” online—assurances their ads are not undermined by being placed to hate speech or other content harmful to their brands—is really about seizing greater control over their own digital futures. They deeply dislike (link is external) the clout that both Google and Facebook have today over the digital advertising system. We are at a critical moment in the brief history of the Internet and digital media. There is greater awareness of what is at stake—including the future of the democratic electoral process—if we don’t develop the regulations and policies that ensure privacy, promote individual autonomy, and place limits on the now-unchecked corporate power of digital marketers. It’s time to expand the focus of the debate about Facebook and Google to include those who have been paying for all of this consumer surveillance—namely advertisers and the advertising industry. They need to be held accountable if we are to see a global digital medium that puts people—not profits—first.

Internet service provider (ISP) giants, which dominant how Americans gain access to broadband Internet, cable TV, streaming video, and other telecommunications services, are aggressively expanding their capabilities to gather and use personal data. Leading ISPs AT&T, Comcast and Verizon are taking full advantage of all information flowing from PC’s, mobile phones, set-top boxes, and other devices. ISP giants are using “Big Data” analytics, artificial intelligence, and an array of cutting-edge technologies to identify who we are, what we do and how best to target us with marketing and advertising. They are also working closely with data brokers to gain access to even more personal information. AT&T, Comcast and Verizon, for example, work with Acxiom’s LiveRamp (link is external) subsidiary to build robust profiles that help them identify us regardless of what devices we may be using at the moment. ISPs envision a future in which we are continuously connected to their vast digital media networks for nearly everything we do. Through their monopolistic control over key broadband, cable TV, and satellite networks, ISPs are able to closely monitor what we do online—including both in and out of home, school or work. Marketers are told by ISPs that they can use their data and networks to “micro-target” an individual on all their “screens,” including for financial, health, retail and even political advertising. They are also positioning themselves to play an important role as our society is further transformed by digital technology, such as with so-called “smart homes,” (link is external) “connected cars,” the Internet of Things (link is external), and high-speed “5G (link is external)” networks. Last year, the Republican majority in Congress and the Trump administration eliminated (link is external) what have been the only federal consumer privacy protections afforded to all Americans—safeguards enacted in October 2016 by the Federal Communications Commission (FCC) that required ISPs to engage in responsible data practices. ISPs saw that important FCC data-protection safeguard as a formidable obstacle to their plans to “monetize” consumer data. With Network Neutrality—a critical requirement to ensure an open and democratic Internet—also ended by the same FCC, phone and cable ISPs have vanquished federal protections for fair treatment of consumers online—including with their data. Unless states weigh in with safeguards, AT&T, Comcast, Verizon and other major ISPs will pose—despite their denials—a major threat to consumer privacy. With ISPs especially touting their prowess to capitalize on a consumer’s location, states have an especially important role to play protecting the public from “hyper-local targeting” and other geo-marketing practices. Here are just some recent developments on ISP consumer data and digital marketing practices. AT&T, according to the Trump administration’s Department of Justice filing (link is external) opposing its acquisition of Time Warner, is “the country’s largest distributor of traditional subscription television; the second largest wireless telephone company, third largest home internet provider; one of the largest providers of landline telephone service; and also the country’s largest Multichannel Video Programming Distributor (MVPD), with more than 25 million subscribers.” Its control over broadband, satellite, and mobile telecommunications services is a key reason why AT&T tells marketers that it has “More Scale, More Targeted, More Screens…advanced TV and multi-screen solutions for your brand.” Last February, trade publication DigiDay leaked AT&T’s “pitch deck (link is external)—highlighting what it called its “digital video advantage.” That advantage includes “the ability to access the hottest content on TV and across platforms; the ability to reach the multi-platform viewing audience in a single buy; premium and non-skippable inventory” (ads a consumer can’t avoid). AT&T’s DirecTV is positioned by the pitch deck as an effective competitor to streaming video services offered by Amazon, Netflix and YouTube. Through several data advertising platform partners, AT&T offers real-time ad targeting of individuals who view streaming video and other online content. The pitch deck breaks down AT&T’s DirecTV audience, in order to help advertisers more effectively reach Hispanics, African Americans and households with children. Its 2017 “Media kit” explained how the company helps advertisers reach individuals on all their devices, giving marketers the ability to “serve ads to the same target audience on TV and digital devices across tens of billions of impressions.” AT&T especially highlights its deep relationship (link is external) with consumer data providers, including Equifax, Experian, Crossix, Neustar, and Nielsen Catalina. These allies help AT&T target its subscribers with ads promoting loans and other financial services. AT&T Adworks has recently opened (link is external) a “new state-of-the-art-media lab”—an “interactive space designed to inspire marketers…[that] shows the future of media consumption and how marketers can most efficiently reach their targets across any platform.” Designed to reflect how digital media reflects “the consumer’s life,” the lab enables advertisers to “interact” by using “data visualization tools” to see how individuals can be targeted through streaming video, Internet of Things devices, on mobile phones and even via data-enriched outdoor advertising. Comcast: The cable TV colossus, which also operates Universal Studios, NBC, and several digital advertising and technology firms, is committed to better leveraging “Big Data.” Comcast sees itself at the “center (link is external) of the household building connections between users, devices, products, and services.” Comcast is developing capabilities to take better advantage of the insights generated (link is external) by its “systems capable of processing billions of events per day.” This includes identifying actionable data, including in “real time,” generated from its video and Internet platforms. Through its “identity strategy,” (link is external) Comcast plans to deliver a “transformative customer experience” that will market to us online “throughout the customer lifecycle.” To help accomplish this, Comcast is building out its “Big Data” capabilities at the “enterprise level,” including for “event processing, analytics,” storing our information in the cloud, and various forms of digital “testing and optimization.” Comcast’s “Applied Artificial Intelligence (AI)” group (link is external) is working to create “intelligent applications that [can] impact millions of people on a daily basis.” Among its projects involving “machine learning” are ways to “build (link is external) virtual assistants that interact with millions of customers in natural language and automatically find solutions to their needs.” It’s part of a much larger “Technology and Product” research infrastructure at Comcast that has offices in Silicon Valley, Philadelphia, Denver, Chicago and Washington, DC. Comcast is also deploying “blockchain” insights platform technology, which it calls BlockGraph (link is external), to help develop more detailed digital dossiers on consumers so they can be targeted for advertising and other services. Comcast’s “FreeWheel” (link is external) subsidiary, with offices in Paris and other global locations, is an advertising, data management and digital rights management technology company. FreeWheel helps video and digital media companies deploy what it calls a “unified ad management platform.” That system allows clients to engage in “intelligent ad decisioning (link is external) across all devices, environments, and data sets….” FreeWheel’s customers, which for the U.S. market include AT&T’s DirectTV, Fox, Time Warner and Viacom, can use its technologies to “unify audiences across desktop, mobile, OTT (so-called Over-the-Top streaming video), and [cable TV] set-top boxes [to] profitably monetize their content.” Comcast’s growing expansion (link is external) in data-driven marketing—operated by both its Advanced Advertising Group and Spotlight service—involves FreeWheel and other acquisitions, including Visible World and Strata. Strata (link is external), for example, is now partnering with “Choozle,” a Big Data-oriented advertising system that helps marketers target a consumer on social, mobile, video and other platforms. The Comcast’s Strata and Choozle (link is external) alliance “will allow thousands of advertising agencies to access detailed consumer data to execute digital advertising campaigns as conveniently as they would buy local TV advertising.” Comcast’s NBCUniversal division has also deepened its use of data-driven techniques to target its viewers. NBCU has its own “advanced advertising” platform (link is external)—Audience Studio—and is promising marketers that its “Total Audience Delivery” will help target (link is external) a consumer on “digital, linear, mobile and out-of-home viewing.” Its “data-based” profiling of its viewers includes information provided by “set top data from Comcast” and other sources. NBCU’s “Audience Studio Targeted Digital,” for example, enables advertisers to reach “digital (link is external) audiences” who view its portfolio of “entertainment, lifestyle, news, sports and Hispanic” content. Comcast’s NBCU urges advertisers to provide them their own (first-party) information on consumers so it can be merged with the TV network’s data. The result, claims NBCU, is that marketers will reach their “objectives through precision targeting at unequaled scale.” What NBCU means is that the same kinds of sophisticated capabilities that Comcast relies on to reach its broadband consumers are also available through its TV subsidiary. Verizon: To further its plans to harvest consumer information to bolster its “differentiated data” ad-targeting capabilities, Verizon has created a new division called “Oath.” (link is external) Incorporating “50 media and technology brands that engage more than a billion people around the world, the Oath portfolio includes HuffPost, Yahoo Sports, AOL, Tumblr, Yahoo Finance, Yahoo Mail” and other properties. Oath operates a real-time data targeting apparatus called One (link is external). It also owns a leading digital video ad company called BrightRoll (link is external) that delivers targeted marketing in real time to streaming video. The result of Verizon’s investments, it explains, is the “most advanced and open advertising technology” system (link is external) that “spans across mobile, video, search, native and programmatic ads.” Verizon’s Oath promises its clients it delivers “people based marketing (link is external).” People-based marketing is a marketing industry euphemism for using our personal data to identify us online. In the case of Verizon’s Oath, that includes our “location, passions and interest from social (media), purchase intent from search and advertising engagement, cross device identity from users mapped across devices, favorite content from web, app and Smart TV data, on and offline purchases and recent store visits from mobile geolocation data.” Oath explains that its “suite (link is external) of advertising technology lets you activate this data to find and message consumers all along their journey.” Verizon acquired AOL after that company had made its own considerable acquisitions of data targeting companies, including those that access mobile (link is external) data from apps. Consequently, Verizon can claim that “Oath has the industry’s largest mobile demand portfolio to help you monetize across every device…,” including in real-time. This is just a brief snapshot of leading ISP data and digital marketing practices today. ISPs’ unfettered control over broadband communications enable them to eavesdrop on the communications and behaviors of millions of individuals and households. Without consumer safeguards, they will further mushroom into even more formidable—and unaccountable—gatekeepers over our information and privacy.

Computational politics—the application of digital targeted-marketing technologies to election campaigns in the US and elsewhere—are now raising the same concerns for democratic discourse and governance that they have long raised for consumer privacy and welfare in the commercial marketplace. This paper examines the digital strategies and technologies of today’s political operations, explaining how they were employed during the most recent US election cycle, and exploring the implications of their continued use in the civic context.---For the full journal, please visit https://policyreview.info/node/773/pdf (link is external) .

Learn about NCC Digital Media: the primary source for reaching consumers across all screens, helping brands target consumers across all screens. --- For more information, visit http://bit.ly/2gUeYq2 (link is external)

Seven independent ad tech companies debuted a programmatic consortium on Thursday that pools their supply- and demand-side cookie IDs into one shared identity asset. The consortium is helmed by AppNexus, MediaMath and LiveRamp, which provides the data matching. Other launch partners include Index Exchange, Rocket Fuel, LiveIntent and OpenX. And it’s a shot across the bow of Facebook and Google, which suck in a majority of digital ad dollars. “The big giants have had an advantage over the open internet in that they have their own deterministic identities for users that allows more precise targeting and cross-device matching,” said AppNexus product VP Patrick McCarthy. Ad tech platforms like AppNexus, Index Exchange and OpenX have the combined online reach marketers want, McCarthy said, but an advertiser must match its data against each platform independently and use LiveRamp to create one-to-one matches. “A universal cookie ID eliminates all the user syncing that goes on between platforms and the lower match rate that necessarily goes with it,” he said. While Google and Facebook have users who contribute deterministic data, the newly formed ad tech consortium can apply first-party data from advertisers and logged-in data from publishers. Marketers and supply sources who are a part of the consortium will access for free the shared cookie pool. LiveRamp’s cross-device graph IdentityLink can be extended to the campaigns, but LiveRamp is still considering commercial terms for ad buyers who want to add a cross-device matching component, company CMO Jeff Smith told AdExchanger. The lack of a unique identifier to date has been one of the biggest factors in fueling concerns around transparency, fairness and control in the digital advertising ecosystem For now, though, any marketer who wants to take advantage of the consortium’s cross-device offering must be a LiveRamp IdentityLink customer. Smith is acutely aware that LiveRamp gains a new business funnel, noting that onboarding potential consortium partners is “definitely is a benefit for us.” “And hopefully the broader benefit is if everyone standardizes around a common identity, the value and efficiency of their marketing will go up,” he added. While the DSPs and SSPs in the consortium may not view it as a new business play, “there certainly will be benefits” that could lead to budget and supply-source consolidation, said MediaMath product VP Philipp Tsipman. For instance, a European video supplier working with MediaMath on a campaign could match its viewers one-to-one with MediaMath’s cookie pool. If that relationship were to occur through the consortium, the match rates would be higher and the profiles would be more robust, since suppliers across the web are contributing data as well. AppNexus’s McCarthy said the system doesn’t cut off buyers from suppliers that don’t use the consortium, but “they will get better matching and better results, so it could naturally funnel more budgets to suppliers that participate.” The market needs “a unique identifier that is neutral,” said OpenX CEO Tim Cadogan in a statement about joining the consortium. “The lack of a unique identifier to date has been one of the biggest factors in fueling concerns around transparency, fairness and control in the digital advertising ecosystem.” --- For the full article, please visit http://bit.ly/2fLZtAB (link is external)

Released on September 22, 2017 at a political microtargeting conference held in Amsterdam, in response to the recent announcement by Facebook and Mark Zuckerberg on changes to how they conduct political ad campaigns. Dear Mark, Your statements on Facebook’s new policies for political advertising were issued as we started a global symposium on micro-targeting in Amsterdam (https://www.ivir.nl/amsterdam-symposium-on-political-micro-targeting/ (link is external)). We are a group of leading international academic experts and civil society representatives from the fields of law, communication, political science and economics who are conducting research on political targeting. Fairness, equality and democratic oversight are key in democratic societies. We appreciate the initiative you have taken and strongly encourage further dialogue and action. Moving this forward we strongly believe that the principles of transparency and disclosure are essential. Facebook should share publicly the full range of paid political contents, disclose the sponsoring actors, and identify the categories of target audiences. This should be done globally as this is an issue that affects elections worldwide. We encourage you and other platforms and actors to join this dialogue to contribute principles for transparency and disclosure. Transparency is a first step in the right direction. Digital political advertising operates in a dynamic tension between data and humans, commerce and politics, power and participation. Some of these tensions can be resolved by transparency, others not. The way forward is to engage with governments, regulators, election monitoring bodies, civil society and academics to develop public policies and guidelines for ensuring fairness, equality, and democratic oversight in digital political campaigns. Can we count on you? Natali Helberger Institute for Information Law (IViR), University of Amsterdam Claes de Vreese Amsterdam School of Communication Research (ASCoR), University of Amsterdam Balazs Bodo Institute for Information Law (IViR), University of Amsterdam Mauricio Moura George Washington University Max von Grafenstein Alexander von Humboldt Institute for Internet and Society, Berlin Jessica Schmeiss Alexander von Humboldt Institute for Internet and Society Sabrina Sassi Universite Laval Tom Dobber Amsterdam School of Communication Research (ASCoR), University of Amsterdam Jeff Chester Center for Digital Democracy, Washington, DC Kathryn Montgomery American University, Washington, DC André Haller Institut für Kommmunikationswissenschaft, Universität Bamberg Damian Tambini Department of Media and Communications, London School of Economics and Political Science Simon Krischinski Johannes Gutenberg Universität Mains Daniel Kreiss School of Media and Journalism, University of North Carolina at Chapel Hill

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)