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FTC & Google

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Posted on May 21 2018



Federal Register proposed FTC Rule making

 FTC Seeks Comment on

Proposed Amendment to

Privacy Act Notices


🚨April 25, 2018 the FTC announced its intention of proposed (update) ruling making of a 2007 statute. The FTC April 2018 Press Release reads in part:


...”the FTC in 2007 published a new routine use based on model language recommended from the Justice Department that allowed for disclosure of records to appropriate persons and entities in order to respond to a data breach. Since then, the Office of Management and Budget (OMB) determined that the model language was too narrow and that agencies needed authority to make disclosures that go beyond those contemplated by the original routine use.’


Comments CLOSE on June 4, 2018, link to FTC Comment portal here 


Link to the FTC publication in the Federal Register link found here


SUMMARY: The FTC proposes to modify all FTC Privacy Act system of records notices (SORNs) by amending and bifurcating an existing routine use relating to assistance in data breach responses, to conform with Office of Management and Budget (OMB) guidance to federal agencies, OMB Memorandum 17–12.


ADDRESSES: Interested parties are invited to submit written comments by following the instructions in the Request for Comment part of the SUPPLEMENTARY INFORMATION section below. Comments should refer to ‘‘Privacy Act of 1974; System of Records: FTC File No. P072104’’ to facilitate the organization of comments. Please file your comment online at


Link to FTC Comment Portal here  

The landing page will look like this👇🏻 following the instructions on the web-based form. If you prefer to file your comment on paper, mail or deliver your comment to the following address: Federal Trade Commission, Office of the Secretary, 600 Pennsylvania Avenue NW, Suite CC–5610 (Annex J), Washington, DC 20580, or deliver your comment to the following address: Federal Trade Commission, Office of the Secretary, Constitution Center, 400 7th Street SW, 5th Floor, Suite 5610 (Annex J), Washington, DC 20024.


 This 30 second video from last night’s 60 Minutes report shows the totality of Googles monopoly and far reaching data mining capabilities. You should watch it. 

Federal Trade Commission (FTC)



Consent Decrees & Court Orders

2011 2012, 2016 and 2018...



🚩Google Buzz FTC DOCKET NO. C-4336

In 2011 the FTC received numerous complaints against Google and their product Google Buzz aka Buzz. In the FTC compiaint, based on an exhaustive investigation, they found that Google violated data privacy laws. The 2011/2012 FTC Complaint read in part:

See page 5, paragraph 14;


In truth and in fact, as described in paragraphs 7-11, respondent did not use information from consumers signing up for Gmail only for the purpose of providing them with a web- based email service. Instead, Google used this information to populate its new social networking service. Therefore, the representations set forth in paragraph 13 were, and are, false or misleading and constitute a deceptive act or practice.


You can read the full FTC Google Docket & Complaint, here


🔥Google Buzz FTC Order🔥

The Consent Decree & Order between the FTC & Google resulted in the following:

 “Clear(ly) and prominent(ly)” shall mean:

A. In textual communications (e.g., printed publications or words displayed on the screen of a computer or mobile device), the required disclosures are of a type, size, and location sufficiently noticeable for an ordinary consumer to read and comprehend them, in print that contrasts highly with the background on which they appear;

B. In communications disseminated orally or through audible means (e.g., radio or streaming audio), the required disclosures are delivered in a volume and cadence sufficient for an ordinary consumer to hear and comprehend them;

C. In communications disseminated through video means (e.g., television or streaming video), the required disclosures are in writing in a form consistent with subpart (A) of this definition and shall appear on the screen for a duration sufficient for an ordinary consumer to read and comprehend them, and in the same language as the predominant language that is used in the communication; and

D. In all instances, the required disclosures: (1) are presented in an understandable language and syntax; and (2) include nothing contrary to, inconsistent with, or in mitigation of any other statements or disclosures provided by respondent.

IT IS FURTHER ORDERED that, in connection with its compliance with Part III of this order, respondent shall obtain initial and biennial assessments and reports (“Assessments”) from a qualified, objective, independent third-party professional, who uses procedures and standards generally accepted in the profession. ... The reporting period for the Assessments shall cover: (1) the first one hundred and eighty (180) days after service of the order for the initial Assessment, and (2) each two (2) year period thereafter for twenty (20) years after service of the order for the biennial Assessments. Each Assessment shall:


The full FTC Google Buzz Order can be found here in the FTC’s October 2011 Press Release (archived link here) stated:

The settlement resolves charges that Google used deceptive tactics and violated its own privacy promises to consumers when it launched its social network, Google Buzz, in 2010. The agency alleged that the practices violate the FTC Act. The settlement bars the company from future privacy misrepresentations, requires it to implement a comprehensive privacy program, and calls for regular, independent privacy audits for the next 20 years.


🍎2012 FTC v Google Apple Customers🍎


In 2012 the FTC launched additional  investigation based on Consumer complaints. As such the FTC concluded that Google had violated data privacy laws & disclosure laws. As such on August 12, 2012 the FTC Announced:

Google Will Pay $22.5 Million to Settle

This was AFTER the FTC went as far as obtaining a:



Federal Case No. CV 12-04177 SI, found here



The FTC investigation concluded that Google had placed cookies on MAC products without disclosing it to the end user. To read the full FTC for Google


...matter, found here 


the FTC Press Release reads in part:

FTC charged that for several months in 2011 and 2012, Google placed a certain advertising tracking cookie on the computers of Safari users who visited sites within Google’s DoubleClick advertising network, although Google had previously told these users they would automatically be opted out of such tracking, as a result of the default settings of the Safari browser used in Macs, iPhones and iPads. 


2016 Google DoubleClick Ad Policy;

In December of 2016 the Consumer Watchdog & Privacy Rights Clearinhhouse filed a 26 page Complaint with FTC. Their complaint alleges that Google acted in a “highly deceptive manner”, when it changed its its privacy policy in June 2016. This change allowed Google to merge data collected by different services owned by Google, such as Google Maps, Google search and the DoubleClick online advertising service. and failed to notify their customers and the FTC.

See what I mean? Big data = BIGLY problems 

Google indeed has been a serial privacy violator,” said John M. Simpson, privacy project director for Consumer Watchdog. “Something needs to be done that gets their attention.”

Their complaint reads in part:

When Google acquired DoubleClick in 2007, it overcame significant privacy concerns by pledging to Congress, the Federal Trade Commission (FTC), and the public at large not to combine its users’ personally-identifiable information with DoubleClick’s vast browsing data.

These assurances paved the way for the FTC approval of the acquisition.

Nearly a decade later, on June 28, 2016, Google quietly changed its privacy policy to permit the combination of this data, and forced the change on users in a highly deceptive manner, without meaningful notice and consent. The change marked the culmination of a nearly decade-long deception that Google has perpetrated against its users, the FTC, and the public at large. The change also violated legally binding commitments that Google made to the FTC.

By finally combining all of this information, Google has engaged in a dangerously invasive and far-reaching appropriation of user data. And the manner in which Google perpetrated this appropriation makes it that much more vexing and legally actionable: Google has done incrementally and furtively what would plainly be illegal if
done all at once.


You can read the Complaint, Request for Investigation, Injunction, and Other Relief Submitted by Consumer Watchdog andPrivacy Rights Clearing House, here

 The June 2016 Google change was first noted by this ProPublic investigative article, it’s an excellent read and gives you a full picture of Google’s alleged malfeasance. Frankly it’s stunning, see ProPublica Article here

See Google’s 2017 Letter to the FTC, found here 

And let’s not forget the FTC is an enforcement agency, their main charter is to protect our privacy from Behemoth Tech giants like Google, Facebook, Twitter et al...remember the internet is forever and ALWAYS read the terms and conditions of 3rd party apps... 

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