Care About Do-Not-Track? Help Us Submit Comments to the FTC

Have you followed the debate over the Federal Trade Commission’s do-not-track proposal for online ads? Do you have an informed point of view on its implementation and potential impact? If so, ClickZ would like to help your voice be heard.

Last week the FTC issued a preliminary report creating a privacy framework for businesses and policy makers. If adopted in its current form, the document could pave the way for a legislated do-not-track option for Internet users. That in turn could have big consequences for the young digital ad sector.

The FTC is now soliciting comments from interested parties, and ClickZ is planning to submit a feedback document by the January 31 deadline — consisting of the views of our contributors and you, our readers. Our comments will focus in particular on the do-not-track mechanism. And we will approach the process with a neutral stance; that is, we are not reflexively for or against do-not-track.

We ask that interested readers do the following:

1) Read the FTC’s related report, “Protecting Consumer Privacy in an Era of Rapid Change.” (PDF download). Pay special attention to pages 63 to 69, dealing with do-not-track.

2) Read the below section, “FTC Questions for Comment.” These are the specific queries the FTC has issued and would like feedback on. Your comments should be written in the form of answers to one or more of these questions.

3) For context, you can also read our related coverage:

FTC Wants Do-Not-Track for Online Ads

House Meets to Discuss Do-Not-Track

Feasibility of FTC ‘Do-Not-Track’ Option In Doubt

Please limit your written comments to 1,000 words or less. When ready, submit them to us via e-mail at Our editors are on hand to answer any questions you may have about the process. We must receive your submission by January 15, two weeks before the submission deadline, to leave enough time to read and compile them. If we use your comments, we will cite you and/or your company directly.

In late winter and early spring, the FTC will consider your words as it drafts a revised report for release later this year. This report could be the foundation for future legislation, and could influence the way ad targeting works on the Internet going forward.

FTC Questions for Comment

Before sending ClickZ your comments, please read the following list of questions, along with the relevant passages of the FTC’s related report beginning on page 63. Responses that speak directly to these questions will receive higher consideration by our staff and the FTC. When possible, please back up your statements with evidence.

  • How should a universal choice mechanism be designed for consumers to control online behavioral advertising?
  • How can such a mechanism be offered to consumers and publicized?
  • How can such a mechanism be designed to be clear, easy-to-find, usable, and understandable to consumers?
  • How can such a mechanism be designed so that it is clear to consumers what they are choosing and what the limitations of the choice are?
  • What are the potential costs and benefits of offering a standardized uniform choice mechanism to control online behavioral advertising?
  • How many consumers would likely choose to avoid receiving targeted advertising?
  • How many consumers, on an absolute and percentage basis, have utilized the opt-out tools currently provided?
  • What is the likely impact if large numbers of consumers elect to opt out? How would it affect online publishers and advertisers, and how would it affect consumers?
  • In addition to providing the option to opt out of receiving ads completely, should a universal choice mechanism for online behavioral advertising include an option that allows consumers more granular control over the types of advertising they want to receive and the type of data they are willing to have collected about them?
  • Should the concept of a universal choice mechanism be extended beyond online behavioral advertising and include, for example, behavioral advertising for mobile applications?
  • If the private sector does not implement an effective uniform choice mechanism voluntarily, should the FTC recommend legislation requiring such a mechanism?

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