The document is a complaint letter to the Federal Trade Commission regarding Google's failure to offer a "Right to be Forgotten" or "Right of Relevancy" in the United States. It argues that Google's refusal to honor removal requests in the US while doing so in Europe is both unfair and deceptive. The letter provides examples of individuals harmed by embarrassing or irrelevant information being linked to their name in search results and argues that Google's privacy claims are deceptive given it does not offer this important privacy protection to US users. It urges the FTC to investigate whether Google's practices violate consumer protection laws.
Full 2012 FTC report into suspected antitrust by Google (via WSJ)Tric Park
[the] effect ofGoogle's conduct is to diminish the incentives of vertical websites to invest in, and to develop, new and innovative content. In the alternative, Googlc's conduct may be condemned as a stand-alone violation of Section 5. Google has
presented no efficiency justifi cation for its conduct.
Third, Staff has investigated whether Google has employed ru1ticompetifve
contractual restrictions on the a· utomated cross-management of advertising camp,l aigns. .
Google's main rival (Microsoft) has alleged that Googlc is denying Microsoft c ·tical scale
by employing these restrictions, and thus impairing Microsoft's ability to compe e effectively
in the markets for general search and search advertising. We conclude that thes restrictions
should be condemned under Section 2 because they limit the ability of advertisers to make
use of their own data, and as such, have reduced innovation and increased transaction costs
among advertisers and third-party businesses, and also degraded the quality ofGoogle's
rivals in search and search advertising. Google 's proffered efficiency justification for these
restrictions appears to be pretextual.
Fourth, Staff has investigated whether Google has entered into anticomprtive,
exclusionary agreements with websites for syndicated search and search advcrtisrng services.
We conclude that Google's agreements should be condemned under Section 2 because they
foreclose some p01tion of the market, and, although the agreements result in only modest
anticompetitive effects on publishers, the impact of the agreements in denying scale to
competitors is both competitively significant to its main rival (Microsoft) today, as well as a
significant barrier to entry for potential entrants in the longer term. While Googe presents
efficiency justifications for these agreements, on balance, Staff finds them to be nonpersuasive
Full 2012 FTC report into suspected antitrust by Google (via WSJ)Tric Park
[the] effect ofGoogle's conduct is to diminish the incentives of vertical websites to invest in, and to develop, new and innovative content. In the alternative, Googlc's conduct may be condemned as a stand-alone violation of Section 5. Google has
presented no efficiency justifi cation for its conduct.
Third, Staff has investigated whether Google has employed ru1ticompetifve
contractual restrictions on the a· utomated cross-management of advertising camp,l aigns. .
Google's main rival (Microsoft) has alleged that Googlc is denying Microsoft c ·tical scale
by employing these restrictions, and thus impairing Microsoft's ability to compe e effectively
in the markets for general search and search advertising. We conclude that thes restrictions
should be condemned under Section 2 because they limit the ability of advertisers to make
use of their own data, and as such, have reduced innovation and increased transaction costs
among advertisers and third-party businesses, and also degraded the quality ofGoogle's
rivals in search and search advertising. Google 's proffered efficiency justification for these
restrictions appears to be pretextual.
Fourth, Staff has investigated whether Google has entered into anticomprtive,
exclusionary agreements with websites for syndicated search and search advcrtisrng services.
We conclude that Google's agreements should be condemned under Section 2 because they
foreclose some p01tion of the market, and, although the agreements result in only modest
anticompetitive effects on publishers, the impact of the agreements in denying scale to
competitors is both competitively significant to its main rival (Microsoft) today, as well as a
significant barrier to entry for potential entrants in the longer term. While Googe presents
efficiency justifications for these agreements, on balance, Staff finds them to be nonpersuasive
Google's Negotiations with the Chinese Government in 2010Ankur Saxena
This paper chronicles Google’s presence in China during 2005-2010, analyzes Google’s dispute with the Chinese government over China’s Internet censorship requirements in 2010 and discusses how a better outcome could have been achieved for Google.
Google in China presentation by pankajPankaj Joshi
I made this presentation during my MBA days. The purpose of making this presentation was to explain the issues arose when google announced its decision of leaving China. Due to censorship issues. This presentation compares the current situation of that time with future forecasting. Although things are changed right now but this presentation can help people to learn what happened then, and how things got favorable for other search engines and how google tackled the situation. This is based upon the secondary data available in journals, internet.
Google's Negotiations with the Chinese Government in 2010Ankur Saxena
This paper chronicles Google’s presence in China during 2005-2010, analyzes Google’s dispute with the Chinese government over China’s Internet censorship requirements in 2010 and discusses how a better outcome could have been achieved for Google.
Google in China presentation by pankajPankaj Joshi
I made this presentation during my MBA days. The purpose of making this presentation was to explain the issues arose when google announced its decision of leaving China. Due to censorship issues. This presentation compares the current situation of that time with future forecasting. Although things are changed right now but this presentation can help people to learn what happened then, and how things got favorable for other search engines and how google tackled the situation. This is based upon the secondary data available in journals, internet.
Mobilizing Disaster Content: From Source to UseAlbert Simard
Describes the flow of disaster-related content from its source to end use through five processes: monitoring, decision support, integration, transactional knowledge markets, and sequential service markets
The ruling from NY Supreme Court Judge Ferris Lebous that throws out a de facto moratorium passed by the City of Binghamton in December 2011. The judge said the Mayor and City Council did not have a sufficient legal basis to enact a moratorium. The case revolved around whether or not the law as passed was a moratorium. The judge ruled it was and threw it out.
Google Hummingbird: What It Means and What You Can Do About ItSearch Engine Land
Joint presentation from #EktronSynergy conference in Boston MA May 2014 - Given by @MonicaWright (Director of Audience Engagement at @SEngineland & @MarketingLand) and Jim Carney (@JimmCarney ) of @Ektron.
Describes the access to knowledge policy developed by the Canadian Forest Service (2004): Background, policy statements, guidelines, implications, knowledge asset inventory; publication available
Modeling Framework to Support Evidence-Based DecisionsAlbert Simard
Describes a framework for modelling in a regulatory environment founded on sound scientific and knowledge management concepts. It includes 1) demand (isue-driven) and supply (model driven) approaches to modelling, 2) balancing modeler, manager, and user perspectives, 3) documentation to demonstrate due diligence, and a 700-term glossary.
Slides from webinar offered by Acme Packet and the SIP School on securing unified communications borders with Acme Packet. To watch recorded webinar or download slides, visit : http://tiny.cc/securingUC
From www.worldwatch.org/cserms/baseline-report.
Established in 1973, CARICOM is a regional organization representing 15 member state. CARICOM member states, representing a total population of over 17 million people, despite their diversity, face many shared energy challenges. Fortunately, significant renewable energy resources exist across the CARICOM region, including biomass, geothermal, hydropower, solar, waste-to-energy, and wind.
Is it safe to share your location on Foursquare, Gowalla, Facebook, Twitter? Shouldn't we all share more, since only wrongdoers have something to hide? Is it even possible to opt out of sharing in a connected society?
The Firecat Studio First Friday Coworking and Brownbag lunch topic of May, 2011 covered these examples and currently proposed legislation.
Designing for Privacy in an Increasingly Public World — Speed TalkRobert Stribley
Lightning talk version of my Designing for Privacy in an Increasingly Public World presentation for Design Museum Week, presented Wednesday, April 27, 2022
Ethics and Management7Google” Ethics and ManagementIs.docxgitagrimston
Ethics and Management
7
“Google” Ethics and Management
Isaac Moreno, Roy Rexroat, and Christina Ramirez
Hawaii Pacific University
Lindsey A. Gibson, PhD
November 25, 2014
EXECUTIVE SUMMARY
The objective of the review is to provide an ethical and moral perspective within management and to instill a good guidance system for business organizations with estimation on the usefulness and competence of the use of Google’s Internet websites as a communication tool for information distribution. It emphasizes the importance of related issues such as behavior management system, and accessibilities. This information will also discuss the main challenges faced when managing their website. Google has established for a variety of purposes one thing is for sure, is that information dissemination to personnel can be used as a platform to manage e-business applications with top efficiency. A requirement for good ethical behavior is to have an excellent website which can effectively govern online with a functioning decision making mechanism enabling good interaction between key initiatives.
Website governance and strategy must be well devised by having the ability to align and incorporate well with other business strategies. Three of these major strategies deal with communication, funding, and human resources. The execution taking Google to the top would be to use a good website strategy which must be through clear, consistent, and all-inclusive with timely regulations and directive guidelines. The implementation of an ethical system would help centralize all website-related activities. The most important characteristics of a good management system will be out to ease when being used by top management, customizable workflow, high protection and a multilingual foundation.
The current level of employment and related training resources for website management are currently insufficient, considering the significance and impact that websites have on the organizations’ which are mandated. Without appropriate funding and experienced management, a website would lose its effectiveness and value in a short period of time. Having a good management system in an organization are faces various challenges for unifying their web presence through efficient content and having an application of consistent online trademark. Attentiveness should be increased by the organization at large to other departments in which the web can continue to develop, and that it would require considerable and sustained assets in human resources and training.
For most of these challenges, they will curtail from the decentralized structure of most management system and websites in terms of content generation, due to the lack of overall web governance, executive web strategy integrated with business communications, standard guidelines, policies and expertise. Listed below are the suggestions addressed to all departments of Google. Other recommendations proposed for the considerations for top ma ...
Online Behavioral Advertising (OBA) Legal & Regulatory ComplianceAdler Law Group
Behavioral or targeted marketing and advertising is one of the fastest growing areas for advertising and marketing professionals. New technologies driving behavioral and contextual advertising are challenging the established methods. Many realize that limiting targeted marketing may lead to undesired and potentially disruptive consequences, including undermining the implicit bargain that drives the Internet: the exchange of value between consumers and content providers. However, legislators, regulators, and industry trade groups have expressed concerns over perceived abuses of the collection and use of personal data of online users that involve privacy issues that “go well beyond behavioral advertising.” With every technological development and opportunity, new legal and business risks present themselves. Understanding and minimizing these risks will help you maximize the opportunities. Attendees will learn 1) the current state of behavioral and contextual advertising, 2) risks and pitfalls with targeted advertising, and 3) trends in legislation and regulatory compliance.
6Running Head The FBI’s Issue with the Marketing of Privacy.docxevonnehoggarth79783
6
Running Head: The FBI’s Issue with the Marketing of Privacy
The FBI’s Issue with the Marketing of Privacy
Nathaniel Ansah
Davenport University
BUSN 520
Professor Lyncheski
September 30th , 2014
Abstract
Effective marketing is an integral part of any company or organization that wishes to become or remain viable. It is for this reason that most organizations invest a tremendous amount of time, effort, money and resources into executing a marketing strategy that will not only maintain or establish good repute, but will ensure that customers will want to begin or continue to patronize their establishment or utilize their services. While a good marketing plan is usually crafted with the intent to gain the favor of the public, there are times where these campaigns can cause certain parties or individuals to take issue due to the intention or the perceived controversial nature of the campaign. In this essay, I will discuss the FBI’s discontent with Apple and Google’s recent efforts to protect the privacy of their consumers, as well as explain why this is indeed an issue of marketing.
Discussion
In the past, both Apple and Google have come under fire for what many consumers and observers alike have rightly perceived as betrayal of trust and privacy. Time and again, both companies have willfully surrendered Smartphone users’ data to magistrates brandishing subpoenas, warrants, and threats of being held in contempt of court should these companies refuse to comply (Greenburg, 2013). Naturally, this has not sat well with many Apple and Google customers, who have been left wondering if their privacy will be next in line for its blatant and deliberate invasion (Bobic, 2014). In an attempt to revamp their reputation and once again earn the trust of their customers, these companies have since taken drastic measures to ensure that they are never again put in a position wherein they are compelled to betray those who devotedly enlist in their services. Apple has since announced that it will no longer be able to unlock encrypted iPhones or iPads, as these devices will no longer allow user passcodes to be bypassed (Bobic, 2014). In other words, if any government faction wishes to gain access to an individual’s smart-device for the sake of unearthing incriminating evidence, they will have to do so by requesting permission from the user himself, who will then be given the choice to comply with the court mandate, or face jail time (Bobic, 2014).
To further display their commitment to preserving user privacy, Apple has embarked on a marketing campaign which has involved the construction of a webpage outlining their new and improved privacy policies. On this page, Apple makes it clear that, “Unlike our competitors, Apple cannot bypass your passcode and therefore cannot access this data. So it’s not technically feasible for us to respond to government warrants for the extraction of this data from devices in their possession running iOS 8.” (Bobic, 201.
Pli workplace privacy in the year 2013 2013-6-13mkeane
Addresses privacy issues associated with hiring in a social media world, privacy issues associated with BYOD programs; employee privacy rights associated with off-duty activity including Facebook postings and activity protected by lifestyle laws.
Joint ad trade letter to ag becerra re ccpa 1.31.2019Greg Sterling
We strongly support the objectives of the California Consumer Privacy Act (CCPA), but we have notable concerns around the likely negative impact on California consumers and businesses from some of the specific language in the law. We provide this initial comment to provide you with information about the significant importance of a data-driven and ad-supported online ecosystem, industry efforts to protect privacy, and in section III of the letter draw your attention to several areas that can be addressed and improved through the rulemaking process. We will provide more detailed comments over the coming weeks.
a group of locksmiths has filed a new class action lawsuit against Google, Microsoft and Yahoo. They claim the search engines (Google in particular) are deliberately “flooding” organic results with “scam locksmith listings” known to be false.
In an extensive and lengthy argument, Amazon argues that interactions with the Alexa virtual assistant are free speech. That includes both the human speech commands and the AI/robot responses. Interestingly, Amazon cites Search King v. Google for the proposition that Alexa responses are like search results and entitled to the same editorial protections accorded Google under that ruling and related case law
European Court of Justice Press Release GS Media vs. SanomaGreg Sterling
[W]hen hyperlinks are posted for profit, it may be expected that the person who posted such a link should carry out the checks necessary to ensure that the work concerned is not illegally published. Therefore, it must be presumed that that posting has been done with the full knowledge of the protected nature of the work and of the possible lack of the copyright holder’s consent to publication on the internet. In such circumstances, and in so far as that presumption is not rebutted, the act of posting a clickable link to a work illegally published on the internet constitutes a ‘communication to the public’.
Guide on the use of Artificial Intelligence-based tools by lawyers and law fi...Massimo Talia
This guide aims to provide information on how lawyers will be able to use the opportunities provided by AI tools and how such tools could help the business processes of small firms. Its objective is to provide lawyers with some background to understand what they can and cannot realistically expect from these products. This guide aims to give a reference point for small law practices in the EU
against which they can evaluate those classes of AI applications that are probably the most relevant for them.
Matthew Professional CV experienced Government LiaisonMattGardner52
As an experienced Government Liaison, I have demonstrated expertise in Corporate Governance. My skill set includes senior-level management in Contract Management, Legal Support, and Diplomatic Relations. I have also gained proficiency as a Corporate Liaison, utilizing my strong background in accounting, finance, and legal, with a Bachelor's degree (B.A.) from California State University. My Administrative Skills further strengthen my ability to contribute to the growth and success of any organization.
Synopsis On Annual General Meeting/Extra Ordinary General Meeting With Ordinary And Special Businesses And Ordinary And Special Resolutions with Companies (Postal Ballot) Regulations, 2018
In 2020, the Ministry of Home Affairs established a committee led by Prof. (Dr.) Ranbir Singh, former Vice Chancellor of National Law University (NLU), Delhi. This committee was tasked with reviewing the three codes of criminal law. The primary objective of the committee was to propose comprehensive reforms to the country’s criminal laws in a manner that is both principled and effective.
The committee’s focus was on ensuring the safety and security of individuals, communities, and the nation as a whole. Throughout its deliberations, the committee aimed to uphold constitutional values such as justice, dignity, and the intrinsic value of each individual. Their goal was to recommend amendments to the criminal laws that align with these values and priorities.
Subsequently, in February, the committee successfully submitted its recommendations regarding amendments to the criminal law. These recommendations are intended to serve as a foundation for enhancing the current legal framework, promoting safety and security, and upholding the constitutional principles of justice, dignity, and the inherent worth of every individual.
A "File Trademark" is a legal term referring to the registration of a unique symbol, logo, or name used to identify and distinguish products or services. This process provides legal protection, granting exclusive rights to the trademark owner, and helps prevent unauthorized use by competitors.
Visit Now: https://www.tumblr.com/trademark-quick/751620857551634432/ensure-legal-protection-file-your-trademark-with?source=share
Defending Weapons Offence Charges: Role of Mississauga Criminal Defence LawyersHarpreetSaini48
Discover how Mississauga criminal defence lawyers defend clients facing weapon offence charges with expert legal guidance and courtroom representation.
To know more visit: https://www.saini-law.com/
1. July 7, 2015
Chairwoman Edith Ramirez
Commissioner Julie Brill
Commissioner Maureen K. Ohlhausen
Commissioner Joshua D. Wright
Commissioner Terrell McSweeny
Federal Trade Commission
600 Pennsylvania Avenue, N.W.
Washington, D.C. 20580
Re: Complaint Regarding Google’s Failure To Offer ‘Right To Be Forgotten’ In The U.S.
Dear Chairwoman Ramirez and Commissioners Brill, Ohlhausen, Wright and McSweeny:
I am writing on behalf of Consumer Watchdog, a nationally recognized nonprofit,
nonpartisan consumer education and advocacy organization, to formally lodge a complaint about
Google’s failure to offer U.S. users the ability to request the removal of search engine links from
their name to information that is inadequate, irrelevant, no longer relevant, or excessive. In
Europe the ability to make this request is popularly referred to as the Right To Be Forgotten. As
Commissioner Brill has suggested it may more accurately be described as the Right Of
Relevancy or the Right To Preserve Obscurity.1
Google’s refusal to honor the right and consider
such removal requests in the United States while holding itself out to be concerned about users’
privacy is both unfair and deceptive, violating Section 5 of the Federal Trade Commission Act.
We urge the Commission to investigate and act.
Here is why the Right To Be Forgotten – or Right of Relevancy – is so important to
protecting consumers’ privacy in the digital age: Before the Internet if someone did something
foolish when they were young – and most of us probably did – there might well be a public
record of what happened. Over time, as they aged, people tended to forget whatever
embarrassing things someone did in their youth. They would be judged mostly based on their
current circumstances, not on information no longer relevant. If someone else were highly
motivated, they could go back into paper files and folders and dig up a person’s past. Usually
this required effort and motivation. For a reporter, for instance, this sort of deep digging was
routine with, say, candidates for public office, not for Joe Blow citizen. This reality that our
youthful indiscretions and embarrassments and other matters no longer relevant slipped from the
general public’s consciousness is Privacy By Obscurity. The Digital Age has ended that.
Everything – all our digital footprints – are instantly available with a few clicks on a computer or
taps on a mobile device.
1
Julie Brill, Privacy in the Age of Omniscience: Approaches in the United States and Europe,
https://www.ftc.gov/system/files/documents/public_statements/581751/140911mentorgroup.pdf
2. 2
In fact the Right of Relevancy is also recognized in some U.S. laws. For example the
Fair Credit Reporting Act, which the FTC also enforces, requires that after a certain period of
time – seven years in most cases – information about debt collections, civil lawsuits, tax liens,
and even arrests for criminal offenses become obsolete and must be taken out of consumer
reports.2
Google’s anti-consumer behavior around privacy issues is deceptive. The Internet giant
holds itself out to be committed to users’ privacy, but does not honor requests that provide a key
privacy protection. Google explains: “We know security and privacy are important to you – and
they are important to us, too. We make it a priority to provide strong security and give you
confidence that your information is safe and accessible when you need it. We’re constantly
working to ensure strong security, protect your privacy, and make Google even more effective
and efficient for you.3
” Recently Google said, “Protecting the privacy and security of our
customers’ information is a top priority, and we take compliance very seriously.4
” In its Privacy
& Terms Technologies and Principles Google claims, “We comply with privacy laws, and
additionally work internally and with regulators and industry partners to develop and implement
strong privacy standards… People have different privacy concerns and needs. To best serve the
full range of our users, Google strives to offer them meaningful and fine-gained choices over the
use of their personal information.5
”
In other words the Internet giant aggressively and repeatedly holds itself out to users as
being deeply committed to privacy. Without a doubt requesting the removal of a search engine
link from one’s name to irrelevant data under the Right To Be Forgotten (or Right to Relevancy)
is an important privacy option. Though Google claims it is concerned about users’ privacy, it
does not offer U.S. users the ability to make this basic request. Describing yourself as
championing users’ privacy while not offering a key privacy tool – indeed one offered all across
Europe – is deceptive behavior.
Not offering Americans a basic privacy tool, while providing it to millions of users across
Europe, is also an unfair practice. Acts or practices by a business are unfair under Section 5 of
the Federal Trade Commission Act if they cause or are likely to cause substantial injury to
consumers that consumers cannot reasonably avoid themselves and that is not outweighed by
countervailing benefits to consumers or competition.6
Here are some examples of people who
have been harmed by Google’s refusal to honor Right of Relevancy or Right To Be Forgotten
removal requests in the United States. Clearly there is no countervailing benefit in continuing to
link to the items from search results. Consider these examples:
2
15 U.S.C. § 1681c.
3
Google Privacy & Terms FAQ, http://www.google.com/policies/faq/, accessed April 27, 2015
4
Our commitment to protecting your Google Apps information,
http://googleforwork.blogspot.com/2015/04/our-commitment-to-protecting-your-Google-Apps-
information.html, accessed April 27, 2015
5
Privacy& Terms Technological Principles, http://www.google.com/policies/technologies/,
accessed April 27, 2015.
6
15 U.S.C. § 45(n)
3. 3
• A young California woman was decapitated in a tragic auto accident. Photos from the
grisly accident scene were wrongfully leaked by California Highway Patrol officers and
posted to the Internet. A search on her name still returns the horrible photographs.7
• A guidance counselor was fired in 2012 after modeling photos from 20 years prior
surfaced. She was a lingerie model between the ages of 18-20, and she had disclosed her
prior career when she first was hired. Despite this, when a photo was found online and
shown to the principal of her school, she was fired.8
• A Florida doctor locked herself in the bedroom to hide from her violent boyfriend. He
used a steak knife to jimmy the door open. As he entered she scratched his chest with her
fingernails. When the police arrived, both she and her boyfriend were arrested, her
boyfriend having claimed the scratches on his chest were from the knife. She was
charged with aggravated assault with a deadly weapon and battery domestic violence.
The charges against were soon dropped. Soon after her photo showed up on a mug-shot
website. Anyone who Googled her name found this information as one of the top results.
The mug-shot websites demanded hundreds of dollars to remove the photos. 9
Honoring the Right To Be Forgotten, or Right To Relevancy, is an important tool to
protect privacy. Google’s own experience in Europe demonstrates that Right To Be Forgotten
removal requests can be managed in a way that is fair and not burdensome for Google. Since
Google began considering Right To Be Forgotten requests last May, Google has received
274,462 removal requests. The Internet giant evaluated 997,008 URLs for removal from its
search results, and has dropped 348,794 or 41.3 percent. It declined to remove 495,673, or 58.7
percent of the links.10
Here are some of those cases:
• A woman in Italy requested that Google remove a decades-old article about her
husband’s murder, which included her name. The page was removed from search results
for her name.
• A Swiss financial professional asked Google to remove more than 10 links to pages
reporting on his arrest and conviction for financial crimes. Google did not remove the
pages from search results.
7
The Solace of Oblivion, Jeffrey Tooben, The New Yorker,
http://www.newyorker.com/magazine/2014/09/29/solace-oblivion, accessed April 28, 2015
8
Manhattan HS guidance counselor stripped of job over steamy photo past, Susan Edelman,
New York Post, http://nypost.com/2012/10/07/manhattan-hs-guidance-counselor-stripped-of-
job-over-steamy-photo-past/, accessed April 28, 2015
9
Mugged by a Mug Shot Online, David Segal, The New York Times,
http://www.nytimes.com/2013/10/06/business/mugged-by-a-mug-shot-
online.html?pagewanted=all&_r=3&, accessed April 28,m 2015
10
Google Transparency Report, European privacy requests for search removals,
http://www.google.com/transparencyreport/removals/europeprivacy/?hl=en, accessed June 24,
2015
4. 4
• A rape victim in Germany asked Google to remove a link to a newspaper article about the
crime. The page was removed from search results for the individual’s name.
• Google received multiple requests from an Italian asking Google to remove 20 links to
recent articles about his arrest for financial crimes committed in a professional capacity.
Google did not remove the pages from search results.
• A media professional in the UK asked Google to remove four links to articles reporting
on embarrassing content he posted to the Internet. Google did not remove the pages from
search results.
• An Italian crime victim asked Google to remove three links that discuss the crime, which
occurred decades ago. The pages were removed from search results for her name.
• In the UK a man asked Google to remove links to articles on the Internet that reference
his dismissal for sexual crimes committed on the job. Google did not remove the pages
from search results. 11
Interestingly enough, Google says it will remove certain types of links from its search
results in the United States: “We want to organize the world’s information, but some content on
the web is sensitive or not appropriate for everyone to see… When it will help keep you safe and
avoid harm, we may remove personal information from Google Search results. 12
” Google lists
the following information as data that it will remove: National identification numbers like U.S.
Social Security Number, Argentina Single Tax Identification Number, Brazil Cadastro de
pessoas Físicas, Korea Resident Registration Number, China Resident Identity Card, etc.; Bank
account numbers, credit card numbers, images of signatures.13
Google just announced it would
honor requests to remove links from its search results to so-called “revenge porn” – nude or
explicit photos posted without the subject’s consent.14
Google’s approach to removals in the
United States underscores the unfairness of offering the Right To Be Forgotten to Europeans, but
not to Americans. As clearly demonstrated by its willingness to remove links to certain
information when requested in the United States, Google could easily offer the Right To Be
Forgotten or Right To Relevancy request option to Americans. It unfairly and deceptively opts
not to do so.
It is important to understand what the Right To Be Forgotten or Right to Relevancy as
implemented by the Internet giant in Europe does and does not do. It is not censorship. It does
not remove content from the Web. It would not raise First Amendment issues in the United
States. The right simply allows a person to request that links from their name to data that is
11
Ibid
12
Google Removal Policies, https://support.google.com/websearch/answer/2744324, accessed
April 27, 2015
13
Ibid
14
“Revenge Porn” and Search, Google Public Policy Blog,
http://googlepublicpolicy.blogspot.com/2015/06/revenge-porn-and-search.html, accessed June
24, 2015
5. 5
inadequate, irrelevant, no longer relevant, or excessive be removed from search results.
Americans deserve the same ability to make such a privacy-protecting request and have it
honored.
Now, the Right To Be Forgotten in Europe is simply restoring the balance provided with
Privacy By Obscurity for the Digital Age. The right simply allows a European to identify links
that are no longer relevant and ask for their removal. Removal won’t always happen, but the
balance Google has found between privacy and the public’s right to know demonstrates Google
can make the Right to Be Forgotten or Right To Relevancy work in the United States. The
Internet giant’s current approach of refusing to do so while claiming to protect users’ privacy is
both unfair and deceptive. Consumer Watchdog calls on the Commission to act.
Sincerely,
John M. Simpson
Privacy Project Director
Cc: Jessica Rich, Director Bureau of Consumer Protection; Chris Olsen, Deputy Director
Bureau of Consumer Protection