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‘Doodle 4 Google’ Gaffe Suggests Company Did Not Live Up to Privacy Commitments Made to End Wi-Spy Probe, Consumer Watchdog Tells FTC

WASHINGTON March 1, 2011

David Vladeck

Ed Markey Joe Barton John M. Simpson

http://www.consumerwatchdog.org/resources/ltrvladeck030111.pdf

Last October the FTC noted that among the reasons it was dropping the Wi-Spy investigation was that "Google has recently announced improvements to its internal processes to address some of the concerns raised above including appointing a director of privacy for engineering and product management; adding core privacy training for key employees; and incorporating a formal privacy review process into the design phases of new initiatives."

http://www.ftc.gov/os/closings/101027googleletter.pdf

"The Bureau ended its Wi-Spy probe because it believed Google was implementing improved privacy procedures.  However, the Doodle 4 Google incident shows the Internet giant still does not get it and its processes are inadequate," wrote Simpson. "I urge the Bureau to hold Google accountable for its failure and to ensure that Google executives understand their responsibility to protect consumers’ privacy in the future.  If a company is able to avoid meaningful penalties with empty promises of improved future behavior, the entire regulatory and enforcement process is undermined."

In the "Doodle 4 Google" contest, the company invites "K-12 students to use their artistic talents to think big and redesign Google’s homepage logo for millions to see."  Consumer Watchdog said Google’s handling of the children’s personal identifiable information raises these questions:

  • Did Google actually follow through on its commitments to the FTC to incorporate a formal privacy review for new programs?  Or were those promises hollow, and is "Launch First, Fix Later" still in the marching orders at Google?  
  • If the "Doodle 4 Google" program did go through a formal privacy review, who approved the collection of birthplace and Social Security number data?  By what criteria within Google was this deemed appropriate?
  • While Google eventually stopped gathering the Social Security data, why did Google continue to collect birthplace information about these children?  Has the director of privacy within Google actually approved this? Were other, less intrusive requests ever considered?
  • Google claims that the Social Security numbers "were not entered into [its] records and will be safely discarded," which seems self-contradictory.  If the numbers weren’t entered into Google’s systems, then where are they being stored until being discarded?

Consumer Watchdog has been working to protect consumers’ online privacy rights and educate them about the issues through its Inside Google Project. The goal has been to convince Google of the social and economic importance of giving consumers control over their online lives. By persuading Google, the Internet’s leading company, to adopt adequate guarantees, its policies could become the gold standard for privacy for the industry, potentially improving the performance of the entire online sector.

Consumer Watchdog Washington, DC Santa Monica, Ca. www.consumerwatchdog.org http://insidegoogle.com .

SOURCE Consumer Watchdog

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