We offered comments to the Federal Trade Commission on the implications of algorithmic decision tools used in consumer advertising and marketing campaigns. We made several recommendations to the FTC:
Lack of visibility into online advertising practices and technologies is an impediment to effective consumer protection. The FTC should encourage digital ad platforms to open all ads and targeting criteria to public scrutiny.
Advertising algorithms can play a meaningful role in discriminatory advertising, separate and apart from advertiser targeting choices. The FTC should encourage further study, particularly as to how ad platform optimization relates to equitable delivery of ads for credit, housing, and employment.
Many companies claim to be using social media data to help make important decisions about consumers, despite platform policies that prohibit such uses. The FTC should consider investigating companies that violate platform policies in ways that might harm consumers.