Many businesses have implemented occupational health and safety reviews and audits to assess effectiveness of their OH&S management systems. Conducting these activities on their own, however, businesses may not obtain objective results to provide a com…

It's absurd to suggest that ensuring privacy online threatens the economic well-being of the Internet.

So you dismiss out of hand as “absurd” the concerns of essentially everyone (besides yourself and the other self-appointed “privacy advocates”) who commented last year on the FTC's initial proposed Principles? Even the FTC recognized, in issuing the final principles, the need to “balance the potential benefits of behavioral advertising against the privacy concerns.” So if there's an “absurd” position outside the mainstream of the debate here, it's the one that denies that there's any trade-off at all between restricting targeted advertising (and the data collection that drives it) and the amount of ad revenue available to fund the Internet's future.

What, exactly, do you mean by “ensuring privacy online,” anyway? Mandating opt-in “before any data are collected” as you suggested in your FTC comments last year?

Tell us, what effect do you think that requirement would have on the “economic well-being of the Internet,” as you put it? More to the point, what do you think would be the effect of such a draconian requirement on consumers of advertising-supported online content and services? Do you think these offerings will just continue to fall like manna from heaven? If you do recognize that there's a trade-off here, do you see some alternative that could make up for the reduced growth (or even actual reductions) in ad revenues?

The Internet should not be immune to consumer protection policies (including such critical areas as when seeking a mortgage, getting a loan or researching a medical condition or treatment).

The Internet is already subject to the same basic consumer protection law that governs the rest of the economy—the one against unfair and deceptive trade practices enforced by the FTC. As Adam and I have made clear, we view FTC enforcement of corporate private policies (and other terms of use) as the ultimate layer in the layered approach we have called for. But if you want to go farther than that, the burden rests on you to explain why we need to do so. Specifically, you need to tell us what the harm is.

As one investigates the technologies and business models at the core of the threat to online privacy, it's clear that the ever-growing digital profiling, tracking, and targeting across sites and platforms threaten privacy and also consumer welfare.

If this is so “clear” to you, please, enlighten us. How, exactly, are consumers harmed by profiling, tracking or targeting? And what does a threat to “privacy” really mean?

Individual liberty, in my opinion, is also at stake when someone is using the power of online marketing to influence your opinions and actions in a non-transparent way.

Really? How so? How is my liberty comprised by being shown ads geared towards my interests? Am I unfree because someone might actually try to—horror of horrors!—change my mind about something?

You seem to be suggesting suggesting that advertising produces “false consciousness,” such that the user's thoughts are not really their own if influenced by advertising, or if that advertising was specifically targeted to them. If that's really what you're saying, why don't you just come out and admit that you share Marx's conviction in the inherent manipulativeness of advertising? If that's not what you're saying, please enlighten us as to your theory of how targeted advertising actually threatens individual liberty.

The FTC has made advances in its capacity to research and analyze the issue, hence its new principles. I urge the authors to spend more time doing first-hand research, so they can more knowledgeably participate in the debate.

Are you always this condescending to those who don't share your opinions?

Now, speaking of “first-hand research,” what have you done to show the real harm created by targeted advertising? We're actually trying to suggest real solutions that empower users, while you rant about conjectural harm.

So, again: What's the harm, Jeff? Where's your evidence? If you're going to point to polling data to support an argument based on consumer expectations, I'd really love to hear how you overcome the objections raised by Solveig Singleton and Jim Harper in their outstanding study, “With A Grain of Salt: What Consumer Privacy Surveys Don't Tell Us.” As I've noted before, “Seeing what users actually do in real life says a lot more about their preferences than merely polling them about what they think they care about in the abstract.” The reality is that most people just don't seem as bothered by targeted advertising as you think they should be. Another case of “false consciousness,” perhaps?

It's absurd to suggest that ensuring privacy online threatens the economic well-being of the Internet.

So you dismiss out of hand as “absurd” the concerns of essentially everyone (besides yourself and the other self-appointed “privacy advocates”) who commented last year on the FTC's initial proposed Principles? Even the FTC recognized, in issuing the final principles, the need to “balance the potential benefits of behavioral advertising against the privacy concerns.” So if there's an “absurd” position outside the mainstream of the debate here, it's the one that denies that there's any trade-off at all between restricting targeted advertising (and the data collection that drives it) and the amount of ad revenue available to fund the Internet's future.

What, exactly, do you mean by “ensuring privacy online,” anyway? Mandating opt-in “before any data are collected” as you suggested in your FTC comments last year?

Tell us, what effect do you think that requirement would have on the “economic well-being of the Internet,” as you put it? More to the point, what do you think would be the effect of such a draconian requirement on consumers of advertising-supported online content and services? Do you think these offerings will just continue to fall like manna from heaven? If you do recognize that there's a trade-off here, do you see some alternative that could make up for the reduced growth (or even actual reductions) in ad revenues?

The Internet should not be immune to consumer protection policies (including such critical areas as when seeking a mortgage, getting a loan or researching a medical condition or treatment).

The Internet is already subject to the same basic consumer protection law that governs the rest of the economy—the one against unfair and deceptive trade practices enforced by the FTC. As Adam and I have made clear, we view FTC enforcement of corporate private policies (and other terms of use) as the ultimate layer in the layered approach we have called for. But if you want to go farther than that, the burden rests on you to explain why we need to do so. Specifically, you need to tell us what the harm is.

As one investigates the technologies and business models at the core of the threat to online privacy, it's clear that the ever-growing digital profiling, tracking, and targeting across sites and platforms threaten privacy and also consumer welfare.

If this is so “clear” to you, please, enlighten us. How, exactly, are consumers harmed by profiling, tracking or targeting? And what does a threat to “privacy” really mean?

Individual liberty, in my opinion, is also at stake when someone is using the power of online marketing to influence your opinions and actions in a non-transparent way.

Really? How so? How is my liberty comprised by being shown ads geared towards my interests? Am I unfree because someone might actually try to—horror of horrors!—change my mind about something?

You seem to be suggesting suggesting that advertising produces “false consciousness,” such that the user's thoughts are not really their own if influenced by advertising, or if that advertising was specifically targeted to them. If that's really what you're saying, why don't you just come out and admit that you share Marx's conviction in the inherent manipulativeness of advertising? If that's not what you're saying, please enlighten us as to your theory of how targeted advertising actually threatens individual liberty.

The FTC has made advances in its capacity to research and analyze the issue, hence its new principles. I urge the authors to spend more time doing first-hand research, so they can more knowledgeably participate in the debate.

Are you always this condescending to those who don't share your opinions?

Now, speaking of “first-hand research,” what have you done to show the real harm created by targeted advertising? We're actually trying to suggest real solutions that empower users, while you rant about conjectural harm.

So, again, what's the harm, Jeff? Where's your evidence? If you're going to point to polling data to support an argument based on consumer expectations, I'd really love to hear how you overcome the objections raised by Solveig Singleton and Jim Harper in their outstanding study, “With <span class=”searchword”>A</span> <span class=”searchword”>Grain</span> <span class=”searchword”>of</span> Salt: What Consumer Privacy Surveys Don't Tell Us.” As I've noted before, “Seeing what users actually do in real life says a lot more about their preferences than merely polling them about what they think they care about in the abstract.” The reality is that most people just don't seem as bothered by targeted advertising as you think they should be. Another case of “false consciousness,” perhaps?