Submission Number: 00059
Received: 5/2/2011 12:00:00 AM
Commenter: Judith Bush
Agency: Federal Trade Commission
Initiative: Proposed Consent Agreement In the Matter Google, Inc. (Google Buzz), File No. 1023136
Attachments: No Attachments
To the FTC,
I am submitting this comment on the proposed consent order, In the Matter of Google Inc., File No. 1023136, between the FTC and Google. The consent order comes as a result of the complaint filed by the Electronic Privacy Information Center ("EPIC") regarding the privacy breach to Gmail users caused by Google Buzz.
The Personal Data Ecosystem Consortium, a community of technology innovators and end user advocates has prepared a response to your December 2010 FTC White Paper: __Protecting Consumer Privacy in an Era of Rapid Change, A Proposed Business and Policy Framework__. The comment to that white paper was received at by the FTC and noted at http://www.ftc.gov/os/comments/privacyreportframework/00472.html
Any FTC settlement agreement with Google over privacy issues from the Google Buzz launch should be in alignment with the larger plans to protect consumer privacy. Please consider the comments of Personal Data Ecosystem Consortium in relation to this specific case. I'll list some points from the response and specific points of relevancy with this agreement below:
* People are the Only Ethical Integration Point for Disparate Data Sets: Individuals should be able to decide how to integrate data sets Google (and any other provider) collects about them over disparate services. For example, a person should be able to choose whether or not their Google Talk history should be associated with Buzz -- similarly, they should be able to export their AOL IM history in a manner that Google could use to support Buzz if they wish.
* Service Providers Must Work For the End-User: Google must use open standards when collecting data about users and exporting that data back to users for users to employ as they see fit.
* Personal Data should be treated like Personal Money. -- Thus Google should encrypt their cloud-based service, and never disclose that data without a user's consent, except to law enforcement when served with a proper warrant.
* Consumers need to be able to to Collect and Aggregate Their Data from Product and Service Providers: For example, SMS and instant messaging histories could be aggregated from different providers by a user and then provided to a service which could estimate the most effective way to communicate with specific persons (Friend A is on the same cell provider, so cell to cell calls are "free," Friend B has a IM account which is cheaper than the SMS account texts). This also means that if a user wants to keep their data history, they should be able to allow a service like Google to persist their history in some way. Conversely, they should also be able to indicate that they want their data collection limited to the shortest time possible.
Thank you for your attention,