Can having the wrong friends online affect your credit rating?
I understand the idea behind marketers identifying users who have a lot of friends or are very active online and considering them “influencers”. I “get” the marketing value of enhancing a users profile with information from a range of their online public activity. Providing transparency to users and control over this type of data collection is certainly a challenge, but with enough effort and care about how the data is used, it should be possible to design an ethical framework for responsible practices for social network data use.
But I think this story about lenders being pitched the idea of my social network friends being used to influence my credit is a very, very bad idea. This is the kind of idea that convinces lawmakers and advocates that the entire behavioral advertising business model is unacceptable. I hope Rapleaf will rethink this one.Did blogging about this just adjust my network behavior credit score?
Rapleaf, which has harvested data from blogs, online forums, and social networks, says it follows the network behavior of 480 million people. It furnishes friendship data to help customers fine-tune their promotions. Its studies indicate borrowers are a better bet if their friends have higher credit ratings. This might mean a home buyer with a middling credit risk score of 550 should be treated as closer to 600 if most of his or her friends are in that range, says Rapleaf CEO Auren Hoffman.
Such intelligence could prove useful for a financial company. While no one would automatically green-light borrowers based on their friends, the friendship data could lead them to assign a human to see if the mathematical model is missing something. “They pay more than $100 in marketing to [attract] customers,” Hoffman says. “If they reject you, they lose it.”
Obama Adds Senior Security/Privacy Role to White House Staff
It is very heartening to see the important new office of the Cyber Security Coordinator include a dedicated privacy official. Fighting terror, cybercrime or identity theft all call for strong measures that can require access to personal data of Americans. By having a respected senior voice at the table, privacy issues can be properly vetted when key decisions are considered. The Future of Privacy Forum is still hoping for an overall federal CPO or at least a top OMB official to play a broad role at home and abroad as ‘White House Counselor for Privacy’, much like Peter Swire did during the later Clinton years, but we applaud this most recent move as a positive step in the right direction.
iMedia Connection: Where do we draw the line on consumer profiling?
Increasingly, it is the leading members of the business community who are raising the most serious questions about online data use. Is it credible to claim that a user should feel anonymous when their offline data is pulled in to be used for online targeting? Read what a leading online marketer has to say.
IAB Issues Best Practices for Social Ads
So-called “social ads” are those that display data and reflect actions taken by social network members. Recently, the Interactive Advertising Bureau (IAB) released its “Social Advertising Best Practices”, [LINK HERE], developed by a 151-company committee with 218 members including MySpace, Microsoft, Google, Facebook, SocialMedia.com, CBS, Accenture, PriceWaterhouseCoopers LLC, Condé Nast Digital, IDG Entertainment, and Nielsen Online. The report addressed advertising on social platforms, (which it distinguishes from behavioral advertising). Kudos to the IAB and its committee for the attention given to privacy. The report emphasizes the importance of privacy rules that “ensure that data collected from consumers is fone with consumer consent, that consumers have appropriate notice and choice in what and how their data is used, and that data access and use are consistent with the privacy expectation set by the consumer.”
Google's Andrew McLaughlin becomes Deputy CTO.
I have long admired Andrew as one of the most thoughful thinkers at the intersection of business, technology and policy. Good luck to him as he joins the Obama administration as deputy chief technology officer.
What would Supreme Court Nominee Sonia Sotomayor say about behavioral ads and consent?
The following is a guest post from one of our summer legal fellows, Noam Kutler of GWU School of Law.
As many of you reading this blog are aware, FPF focuses a good deal of attention on the issue of online behavioral advertising and the need for greater consumer control and transparency.The FTC has issued stern warnings and Congress is on the case, but what would the third branch of government have to say?
Recently, Justice Scalia provided some insight into his opinion of online privacy rights during a conversation with FPF Co-Chair Jules Polonetsky, but what about Supreme Court nominee Sonia Sotomayor? In her 2002 Specht v. Netscape Communications Corp (306 F.3d 17) opinion, Sotomayor held that online contract terms must be displayed in a manner that provide “reasonably conspicuous notice” to the user. Specht found that a terms of service agreement applying to a downloadable Netscape plug-in which sent data back to the company was invalid because the user was unlikely to notice the agreement prior to downloading the plug-in and therefore could never manifest consent to the agreement’s terms. This line of thought has direct implications on website privacy policies and could give an indication of Sotomayor’s view regarding a user’s consent to web site data collection.
Hopefully, FPF’s recently announced a new project aimed at developing innovative means for notifying web users about online behavioral advertising will be helpful in guiding companies towards the best options for informing users about online data use. Click here to learn more about this initiative.
Privacy Packed Monday: CFP, CAP, Peter Swire
On Monday, June 1st Christopher Wolf and I will be presenting tutorials at Computers, Freedom and Privacy 2009. Christopher will be giving a presentation about Data Mining and I will be discussing profiling from online data. After that I will be rushing over to the Center for American Progress for the release of 3 key reports by FPF Advisory Board member Peter Swire. Join or follow online…webcasts and twitter details available.
Deloitte Event: The Future of Privacy & Data Security
Please be our guest…
The Future of Privacy & Data Security:
A Briefing on Related Legal Issues and Leading Practices
Wednesday, June 3, 2009
5:00pm – 7:00pm
Remarkable developments in privacy and data security law and business practices have already been seen in 2009 and more changes are on the horizon.
Come, hear, and interact with a panel of thought leaders on the latest in this evolving field that has implications for every business.
Among topics to be covered:
1. New Laws and regulations at the federal and state level that impact companies’ data protection obligations
2. The new privacy and data security enforcement environment
3. The current focus on behavioral marketing and a discussion of leading practices consistent with the Federal Trade Commission guidelines
4. Leading privacy and data protection risk management strategies and controls
Speakers include special guests and noted privacy thought leaders, Christopher Wolf and Jules Polonetsky, co-chairs of the think tank, The Future of Privacy Forum. Chris is also a partner at Hogan & Hartson, a leading law firm with a special focus on privacy.
Speakers:
Rena Mears, Partner, Deloitte & Touch LLP, Global & US Leader Privacy & Data Protection
Jules Polonetsky, Co-Chair, The Future of Privacy Forum
Christopher Wolf, Partner and Privacy & Data Security Practice Group Leader, Hogan & Hartson; Co-Chair, The Future of Privacy Forum
