'Do-Not-Track' Dissected: ClickZ Sends Feedback to FTC

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The good news about the Federal Trade Commission's recent proposal for a Do-Not-Track mechanism is that it could give Web users much needed control over their online data. The bad news: That same proposal threatens to disrupt the delicate value-exchange that's still emerging between Internet users and content publishers.

In December, when the FTC unveiled its do-not-track proposal as part of a comprehensive privacy report, it asked for public comments on the document.

This morning, ClickZ submitted feedback on behalf of its readers. The document we sent the FTC summarizes the observations of 17 readers, contributors, and experts regarding the feasibility and potential impact of such a mechanism. It was supplemented with our own extensive reporting on online ad tracking, and the industry's self-regulation efforts.

Interested readers can download our feedback to the FTC in .pdf form at this link. Among the key points:

• Do-not-track could hurt consumers. A mechanism, if adopted en masse, could reduce consumer access to free content, and could erode the quality and relevance of ads they see online.
• Do-not-track could hurt small and niche publishers. Website owners will likely resort to site demographic data and market research to target their ads. This requirement will tend to favor large publishers with research budgets and direct sales forces.
• Do-not-track could hurt innovation. The online ad sector is a fiercely competitive ecosystem where some of the world's brightest technologists, working for well-funded startups, are building products that will define the future of marketing. The risk, should many consumers opt out, is that this innovation would simply migrate elsewhere.
• Do-not-track should not be an all-or-nothing proposition. Any mechanism should allow users to specify not only topics of interest, but also what data types can be collected, who may leverage that data, and how they are permitted to use it. The downside of this is greater user confusion than a simple on/off switch would create.
• Do-not-track should include ad tracking on mobile devices. The future of interactive content and services is mobile and any ad tracking rules should extend to handheld devices.
• Consumer participation may be minimal. It may be that consumers, given the choice will choose not to opt out of ad tracking for the above reasons, and because historically they have not done so.

The FTC's public comment period ends today. Feedback will inform a revision of the privacy report expected later this year.