PI comments on Google's behavioural ad platform

11/03/2009

Google today launched its new advertising platform. Unlike the company’s previous services that were limited to contextual ads on websites (e.g. a website about travel would advertise travel ads served by Google) and search ads (e.g. searching on Google for 'Bahamas' may give you ads for hotels in the Bahamas), Google will now dynamically track users across sites.

The Google system contains some positive features. While other firms are already using this technology, they are not doing so at the scale that Google is proposing. Google is providing a transparency mechanism that will support privacy through a feature that lets individuals see their profile. Few other firms do this.

Google also promises that it will not create categories on 'sensitive' personal information such as medical information. We look forward to further clarification. This commitment does not mean that Google doesn't collect such information as you cross websites or conduct searches. Meanwhile, the public must be informed precisely what is and what is not 'sensitive information'? Financial information? Political interests? Ethnicity? And, importantly, is it possible to merge “non sensitive” data in a way that creates classes of data that are sensitive?

Google, and all other advertisers in the marketplace must ensure that their processes and technologies embed privacy at the earliest stage of development and deployment, rather than merely as an add-on. In the absence of clear information on Google's system, we have to ask:

Is Google open and clear about what they do?

Although there is talk about 20 categories and 600 subcategories, at this time we have no idea what Google’s algorithms can achieve.

Have they communicated openly and honestly with the public about their plans?

We still have insufficient information, so the answer is a clear “no”. Other firms have run public educational campaigns, issued whitepapers, conducted third party audits. Google manages its business by press release.

Do consumers give permission for their information to be used?

It doesn't appear that Google is willing to let users consent to their profiles being developed. So profiles of your movements across websites will be collected until you notice that your information is being collected and mined, at which point you can tell them, through an antiquated system, that you would rather not be tracked. Can this happen even if you don't ever surf on Google's website?

Does Google ensure that it doesn’t use sensitive personal information at all, let alone for advertising purposes?

To date, Google claims that it does not categorise users by sensitive profiles. What is the definition of 'sensitive'? And does Google still collect information on users as they surf to websites with such content? Though they may not disclose this information to third parties, Google could still collect it. Users deserve further clarification.

Is the information anonymised to the extent that even Google doesn't know you?

Does Google collect IP addresses and other information that can be tracked back to you? Is this information ever deleted? What does this information look like? Though Google may show you the profile that eventually gets developed, what other information does Google hold?

Is the information anonymised so that advertisers don't know you?

What information is shared with third parties like advertisers? Do any other institutions have access to your profile? Google, like most other companies, are unlikely to share the profile with advertisers but we need strong safeguards to ensure that this information will not end up being shared with others.

Is this information retained and used for other purposes?

What other information does Google collect, and how is it merged with existing profile data? We have seen some early indications that YouTube user information is combined with this profile; but apparently Gmail information is not. We would like to see strong safeguards, technical when appropriate, that ensure that this information cannot be joined up, even by Google.

Can others access information about users?

How does one get access to his or her profile? Can someone else gain access for any reason? Do you need to log in? If so, what prevents someone else from doing so?

Time and time again over the past five years Privacy International has asked Google to provide detailed information on such questions. We have time and time again urged the company to adopt a policy of openness and transparency. We have yet to receive any indication that the company has moved more than a few microns in this direction.

Simon Davies, director of Privacy International said:

Google might well hype their targeting system as a boon to pet owners, but the reality is that the service will track just about everything you do and everything you’re interested in, no matter how personal or sensitive. We need strong assurances about the types of information that are collected by Google, and how these are shared. In the absence of concrete guarantees we doubt any claims that your future health problems, sexuality, financial problems and erectile dysfunction won't be open for Google to collect.

Yet again Google has developed and launched a major initiative without any consultation with its users. And yet again Google will walk into a privacy minefield.

This is a potentially dangerous development. On a whim the company can join up all its existing services to provide advertisers with an unprecedented CAT scan of its users.

Behavioural targeting does not have to be evil. The technology can be developed in more or less privacy friendly ways. Google has a track-history of going down the anti-privacy route. And again the company has not been open or transparent and has offered little in the way of meaningful privacy assurances.

The privacy threat from Google is growing by the day. It is now time for parliaments and regulators to launch a full investigation of the company.

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