If I were a member of the FTC I wouldn’t necessarily block the Google-DoubleClick merger, but I would set restrictions to protect consumers’ privacy. In a perfect world, with laws like the ones I talked about two posts back, mergers would not present the privacy concerns that they do now, because people would have the freedom to opt out of having any personally-identifiable data collected by the new company and would be able to see and request deletion of any data that the company already has.
However, with the lack of legal privacy protections that exist in today’s world, the Google-DoubleClick deal would result in one entity controlling an unacceptably large amount of information about individual users’ online activities. If I were a member of the FTC I would recommend that Google-DoubleClick implement a tool similar to the AskEraser, allowing users to opt out of having uniquely-identified data collected about them. DoubleClick’s opt-out cookies are a start, but I would be surprised if many people knew about them. I bet most people who see DoubleClick ads online are unaware that the ads are even coming from DoubleClick, and even fewer bother to visit DoubleClick’s home page, the only place from which the opt-out service is available.
I would require Google-DoubleClick to have an easy-to-find opt-out mechanism, accessible via a link on Google’s home page. Opting out would mean that Google-DoubleClick could collect aggregated data about the user, but could not use unique cookie IDs or IP addresses. The opt-out policy would apply to Google’s search engine and other services, as well as to third-party sites that serve ads from DoubleClick.
Additionally, I would require Google-DoubleClick to allow users to review the data that the company has amassed about them and to request deletion of all unique identifiers, including IP addresses and cookie IDs, from the data.
To all readers: I hope you have enjoyed reading my blog. The project is due tomorrow, so this is my last official post, but I will try to update once in a while with new developments in the Google-DoubleClick deal as well as any important Internet-privacy-related news.