In October 2013, Bell announced the launch of a targeted advertising program that uses its customers’ personal information to deliver more “relevant advertising.” The announcement sparked hundreds of complaints with the Privacy Commissioner of Canada and a filing by the Public Interest Advocacy Centre over the same issue with the Canadian Radio-television and Telecommunications Commission.
My weekly technology law column (Toronto Star version, homepage version) notes that nearly a year and a half later, the complaints and filings remain unresolved. The CRTC case has succeeded in placing considerably more information on the public record, however, offering a better perspective on what Bell is doing and why its privacy approach falls short.
From Bell’s perspective, the targeted advertising approach, which it calls RAP or Relevant Ads Program, does not involve the collection of additional information (it already collects whatever is being used) and the company allows users to opt-out of this use of their information if they so choose. Moreover, it argues that the program is similar to what telecom companies in the United States as well as Internet giants such as Google and Facebook offer.
Yet documents now available on the public record reveal that there are important differences creating serious privacy concerns.
First, Bell has adopted an opt-out approach, automatically including millions of customers in its targeted advertising program unless they proactively ask not to be included. In the United States, some of the comparable programs are either opt-in or compensate users for the use of their information. For example, AT&T offers a discount on high-speed Internet services in some locations if customers allow it to track their web browsing history to deliver customized advertising.
Bell’s opt-out approach places the onus entirely on the user, who may not recognize the privacy implications of the system nor feel that they can take the time to opt-out of every unwanted use of their information. The cost-shift to users is precisely why Canada implemented the do-not-call list (which allows for a single opt-out of all unwanted telemarketing calls) and anti-spam legislation backed by an opt-in requirement.
While marketers can usually count on few people opting-out, Bell has revealed that 113,000 customers opted-out of its program in the first year alone. That may be a fraction of the total number of Bell subscribers, but if more than hundred thousand Canadians took the time to opt-out, there are likely many more that share similar concerns.
Second, Bell has access to customer data that is far more extensive than the Internet companies, who are largely limited to profiles based on Internet use. Bell acknowledges in the public record documents that advertisers can create profiles that include age, gender, account location (including postal code), credit score, pricing plan, and average revenue per user.
In addition to the use of financial information, Bell also tracks and retains individual Internet usage. The company offers advertisers profiles based on user interests, which are derived from the websites that users visit. Bell says that it retains Guavus, a U.S.-based data mining company, to assist in its efforts to assess Internet usage. It acknowledges that all website visits are logged for 30 days in a “probe buffer” and that all web addresses are logged in “Context Awareness Engine” for 90 days. The logged information is not aggregated and can be traced to the specific individual.
Moreover, Bell has also built in the capability to track search queries by pulling search terms directly from website address requests. The functionality is currently disabled, but the company says that it envisions using search terms to developed a more detailed user profile to market to advertisers.
The combined power of financial data, location information, and Internet usage gives Bell a remarkably detailed profile of its users. While the company does not disclose the information to third parties, its use of the information still triggers Canadian privacy law. The full profile represents an enormous amount of personal information, which is why the company’s opt-out approach leaves millions of Canadians with inadequate privacy protections.
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There is even more to it than that. There is also ethnic, racial, religious, medical and other profiling. Bell filing states, “The RAP does not involve any specifically racial or ethnic characteristics or profiling.”
“Specifically” is their qualifier. I’m not too sure what that means. Do you?
Bell states that all web activity will be filtered by the content they glean on your activities.
For example, if you are looking for a hot gay date then that fits in their “lifestyle” category and is filtered and non-accessible to RAP customers.
However, they do not filter apps, as their filing shows. So if you use an app called “hot_gay_date” as an example, then that is allowed for the RAP customer and the RAP customer can target gay people based on app name.
Medical is filtered for the web. But if you use any medical app, such as, the liver disease app, then that isn’t filtered and RAP customers can target medical conditions based on app names used.
Everything Bell states they will filter as sensitive is re-exploited by app name.
There are two different things here:
Categories by web, and categories by app.
Lifestyle
Medical
Kid specific
Adult Content
Family & Parenting
Health & Fitness
Food allergies
Religion and Spirituality
The list above is considered sensitive and filtered by Bell. However, it is not sensitive and filtered if you use specific apps that fall in these categories.
In the filing Bell goes on to state financial app’s people use will not be gleaned for the RAP, yet their RAP app categories clearly states “Finance” apps are gleaned.
In their filing Bell states that sensor devices that use apps (ie IoT stuff) is not used by the RAP, yet their filing clearly shows they are gleaning the app names.
The CRTC better wake up to this.
There is no way any average person is going to understand all this from the watered down marketing material which is the RAP policy.
Then there is the location tracking. Bell states they will indeed location track and track your foot traffic (where you are, and where you go).
The amount of info they are taking is vast.
All the better reason to opt out.
Of using Bell altogether. I am happily doing that.
how do u opt out?
You phone Bell and you cancel all of your accounts with them and take your business elsewhere.
take your business where exactly? haha that’s the real problem
To any of Bell’s competitors.
There are any number of local landline phone service providers (most likely your cable company for example) as well as long distance providers, as well as television service providers as well as mobile phone providers.
Likely you will save money too. My monthly (just local calls) phone bill went from over forty dollars a month down to about $8 and that included the long distance we were paying extra for.
Opt out here: http://www.bell.ca/Relevant-Advertising-program
http://www.bell.ca/Relevant-Advertising-program
I suspect you might have to do it for each service that you subscribe too, if there’s more than one.
I did it for my phone, tv, and internet — just to be sure.
If that’s true that is just a super-douchy way of preying on people’s ignorance or tolerance for having to opt-out of forty-eleven things.
Seriously. Who would want to opt out of just one/some and not all?
Bell: You suck donkey balls. Every morning that I wake up, I wake up ever so gleeful that I have no business with you whatever. You couldn’t give me any of your products for free forever to attract my business back to you.
As a business, you need to die and return back to the taxpayers of this country their own cable plant (yes, that’s right — that cable plant belongs to the taxpayers, not you!!) that the century-old government-provided monopoly allowed you to build.
Brian sez:
” Every morning that I wake up, I wake up ever so gleeful that I have no business with you whatever.”
The thing is, Brian, you do not have to be a Bell customer for them to scoop up your info as part of this RAP program.
Bell stated they will collect info from SMS (chat), phone records and more. Thus if anyone you know uses Bell and they communicate with you, then Bell has whatever info from you they can get.
Does it only affect Bell users? No, not at all.
Even if you are not a Bell user this affects you, sad to say. Jumping ship does nothing when it comes to this RAP.
Also, if you are using one of the smaller Internet, telephone and TV providers, know that the line between you and them is still Bell or Rogers. Bell still gets a piece of your money no matter who you go with unless it runs over coaxial cable, in which case Rogers gets the piece.
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I believe this is very much related to the surveillance attack in Ottawa. You can read more here:
http://ottawacanadaundersurveillanceattack.blogspot.ca/