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Google is circumventing GDPR, reveals Brave's investigation for the Authorized Buyers ad business case

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  • 6 min read
  • 06 Sep 2019

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Last year, Dr. Johnny Ryan, the Chief Policy & Industry Relations Officer at Brave, filed a complaint against Google’s DoubleClick/Authorized Buyers ad business with the Irish Data Protection Commission (DPC). New evidence produced by Brave reveals that Google is circumventing GDPR and also undermining its own data protection measures.

Brave calls Google’s Push Pages a GDPR workaround


Brave’s new evidence rebuts some of Google’s claims regarding its DoubleClick/Authorized Buyers system, the world’s largest real-time advertising auction house. Google says that it prohibits companies that use its real-time bidding (RTB) ad system “from joining data they receive from the Cookie Matching Service.” In September last year, Google announced that it has removed encrypted cookie IDs and list names from bid requests with buyers in its Authorized Buyers marketplace.

Brave’s research, however, found otherwise, “Brave’s new evidence reveals that Google allowed not only one additional party, but many, to match with Google identifiers. The evidence further reveals that Google allowed multiple parties to match their identifiers for the data subject with each other.

When you visit a website that has Google ads embedded on its web pages, Google will run a real-time bidding ad auction to determine which advertiser will get to display its ads. For this, it uses Push Pages, which is the mechanism in question here.

Brave hired Zach Edwards, the co-founder of digital analytics startup Victory Medium, and MetaX, a company that audits data supply chains, to investigate and analyze a log of Dr. Ryan’s web browsing. The research revealed that Google's Push Pages can essentially be used as a workaround for user IDs. Google shares a ‘google_push’ identifier with the participating companies to identify a user. Brave says that the problem here is that the identifier that was shared was common to multiple companies. This means that these companies could have cross-referenced what they learned about the user from Google with each other.

Used by more than 8.4 million websites, Google's DoubleClick/Authorized Buyers broadcasts personal data of users to 2000+ companies. This data includes the category of what a user is reading, which can reveal their political views, sexual orientation, religious beliefs, as well as their locations. There are also unique ID codes that are specific to a user that can let companies uniquely identify a user. All this information can give these companies a way to keep tabs on what users are “reading, watching, and listening to online.”

Brave calls Google’s RTB data protection policies “weak” as they ask these companies to self-regulate. Google does not have much control over what these companies do with the data once broadcast. “Its policy requires only that the thousands of companies that Google shares peoples’ sensitive data with monitor their own compliance, and judge for themselves what they should do,” Brave wrote.

A Google spokesperson, as a response to this news, told Forbes, “We do not serve personalised ads or send bid requests to bidders without user consent. The Irish DPC — as Google's lead DPA — and the UK ICO are already looking into real-time bidding in order to assess its compliance with GDPR. We welcome that work and are co-operating in full."

Users recommend starting an “information campaign” instead of a penalty that will hardly affect the big tech


This news triggered a discussion on Hacker News where users talked about the implications of RTB and what strict actions the EU can take to protect user privacy.

A user explained, "So, let's say you're an online retailer, and you have Google IDs for your customers. You probably have some useful and sensitive customer information, like names, emails, addresses, and purchase histories. In order to better target your ads, you could participate in one of these exchanges, so that you can use the information you receive to suggest products that are as relevant as possible to each customer.

To participate, you send all this sensitive information, along with a Google ID, and receive similar information from other retailers, online services, video games, banks, credit card providers, insurers, mortgage brokers, service providers, and more! And now you know what sort of vehicles your customers drive, how much they make, whether they're married, how many kids they have, which websites they browse, etc. So useful! And not only do you get all these juicy private details, but you've also shared your customers sensitive purchase history with anyone else who is connected to the exchange."

Others said that a penalty is not going to deter Google. "The whole penalty system is quite silly. The fines destroy small companies who are the ones struggling to comply, and do little more than offer extremely gentle pokes on the wrist for megacorps that have relatively unlimited resources available for complete compliance, if they actually wanted to comply."

Users suggested that the EU should instead start an information campaign. "EU should ignore the fines this time and start an "information campaign" regarding behavior of Google and others. I bet that hurts Google 10 times more."

Some also said that not just Google but the RTB participants should also be held responsible. "Because what Google is doing is not dissimilar to how any other RTB participant is acting, saying this is a Google workaround seems disingenuous."

With this case, Brave has launched a full-fledged campaign that aims to “reform the multi-billion dollar RTB industry spans sixteen EU countries.” To achieve this goal it has collaborated with several privacy NGOs and academics including the Open Rights Group, Dr. Michael Veale of the Turing Institute, among others.

In other news, a Bloomberg report reveals that Google and other internet companies have recently asked for an amendment to the California Consumer Privacy Act, which will be enacted in 2020. The law currently limits how digital advertising companies collect and make money from user data. The amendments proposed include approval for collecting user data for targeted advertising, using the collected data from websites for their own analysis, and many others.

Read the Bloomberg report to know more in detail.

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