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Samuelson Clinic Helps Create Privacy Complaint Website

Chris Hoofnagle and Jason Schultz
Chris Hoofnagle and Jason Schultz

By Andrew Cohen

Two faculty members at the Samuelson Law, Technology & Public Policy Clinic have helped launch an interactive online service that lets people share privacy complaints about websites and social networks.

Director Jason Schultz ’00 and Senior Fellow Chris Hoofnagle spent two years collaborating on the project with Privacy Rights Clearinghouse (PRC), a San Diego-based nonprofit. The clearinghouse’s new complaint center provides a navigable, centralized forum for consumers to lodge privacy concerns.

A 2009 Hoofnagle-led research study on how people complain about online privacy violations served as a catalyst for the project. The KnowPrivacy study found that while consumers were largely unaware of how websites tracked their online activity, they still wanted more control over their personal information.

“There was a lot of confusion about where to make a complaint,” Hoofnagle said. “Many complaints are filed with industry-run, self-regulatory bodies that often mischaracterize them and rarely refer them to authorities. It also takes 45 minutes to properly file a complaint with the Federal Trade Commission; not exactly a powerful incentive.”

The new online complaint center acts as a clearinghouse for privacy violations and offers consumers a central point of contact. Users can easily log anonymous complaints or share their identity and problem with journalists or government enforcement and consumer protection agencies. PRC, which for nearly two decades took privacy complaints by email and phone, will respond to complaints within one to two business days.

A User-Friendly Approach

Hoofnagle and Schultz helped the privacy rights group design a simple, browser-based system that organizes complaints into smaller sub-categories. If people see a logged complaint and have experienced the same problem, they can note that with one click rather than type up a whole new complaint.

“Many people care about their privacy and are upset when it’s violated,” Schultz said. “But unless there’s an easy way to register and measure those complaints, policymakers won’t have the right metrics to help solve the problems. Our hope is that this tool provides much-needed data to improve and protect privacy online.”

Schultz and Hoofnagle encountered several challenges in constructing the new centralized service. They had to convert old databases into new and more efficient models, figure out how to best steer individuals within the system, and reach consensus on the most practical layout.

Hoofnagle’s 2009 study also debunked a prevailing privacy assumption that consumers are mainly concerned about harm. The data showed that they rarely complained about actual harm, but most expressed concerns about the sale of their personal information.

“Re-conceptualizing the basis of consumers’ concern is important for framing public policy conversations,” Hoofnagle said. “The challenge now is getting consumers to find this tool and explaining to them why it’s different and more effective. One big advantage, from a search optimization standpoint, is that the Privacy Rights Clearinghouse is well-placed in Google and easy to find.”