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Behan

Michael Behan
HONOR 3374
Professor Dryer
29 April 2016
On the Regulation of Data Brokers:
Why Regulation is Necessary and Relevant to Privacy in a Digital Age
For much of human civilization, people have collected data. Data is defined as
facts and statistics collected together for analysis.1 Early census takers collected
information about peoples age, gender, address, ancestry, race, marital status, and more.2
This information was used to get a better understanding of the citizens that the census
takers were gathering information on, including the following: whom they were, where
they came from, and as time went on, their economic status and housing information.
Obtaining this information was and is valuable because it gives the government and other
entities access to data that they may not have gotten otherwise. Data has always been a
valuable tool to improve knowledge, refine information, and improve society.
Now, data is utilized more than ever. The advances in technology have also
allowed data to be digitized. Rather than stacks of paper taking up entire rooms worth of
space, exponentially more amounts of data can be stored in relatively minute physical
spaces. A hard drive no larger than an index card can hold more than two terabytes of
data. For reference, one typed character is approximately one byte of data. In 2013, there

1

Merriam-Webster. "Data." Merriam-Webster. Merriam-Webster, n.d. Web. 15 Apr. 2016.


2

"Census History." United States Census Bureau. US Department of Commerce, n.d. Web. 22
Apr. 2016.

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were approximately four zetabytes of data collected worldwide. If every citizen of the
United States were to take a picture every second of every day for over a month, the
aggregate of those pictures would equal about one zetabyte.3 In the age of the Internet of
Things, the amount of data will only continue to increase, as more and more devices that
previously did not have the capacity to will begin sharing data.
With all of the increases in technology, there are also many more different outlets
to obtain data from. Aside from the governments census data, there is tons of
information available through a quick Google search. Public records, such as drivers
license records, voter registrations, telephone directories, and real estate listings are
readily available to anyone with Internet access via countless devices. Not only that, but
with all of the social media apps and websites that have hundreds of millions of users,
there is self-reported data to be collected through Facebook profiles and likes, tweets, and
Instagram accounts. If someone were to like the Facebook page for the Utah Utes football
team, for example, or post a picture at Rice-Eccles Stadium, data collectors would be able
to add another level of knowledge about that person: he or she is a fan of the Utah Utes.
There is a lot of personal information about nearly everyone out on the web.
While in bits and pieces it may seem inconsequential if someone knows about ones
Facebook likes, or census information, when put together, all of the separate data points
can create a detailed and accurate profile of an individual. Putting together all of that data
is a tall task, but it is the exact work of data brokers. Data brokers are companies that

3

Podesta, John, Penny Pritzker, Earnest J. Moniz, John Holdren, and Jeffrey Zients, comps.
"Big Data: Seizing Opportunities, Preserving Values." (n.d.): n. pag. White House: Executive
Office of the President. May 2014. Web. 17 Apr. 2016.

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collect and aggregate consumer information from a wide range of sources to create
profiles of individuals.4 These profiles tend to be extremely accurate, with some potential
discrepancy depending on when and from where the data was collected. After this
information has been collected, the data is sold to companies including other data
brokers, government agencies, businesses, or other persons. While some data collection
can be beneficial, and assist consumers by giving them tailored offers and advertisements
and the like, with the enormous collection of data, a full profile containing potentially
sensitive personal information can be created. The data broker industry is a multi-billion
dollar industry, is subject to little regulation, and has been often criticized by members of
congress and consumer groups for the lack of transparency about what data is gathered,
to whom it is sold, and how it is used. The FTC divides data brokers in to three broad
categories, depending on the type of product they sell: marketing products, risk
mitigation products, and people search products. 5
Data brokers that sell marketing products enable their clients to create tailored
marketing messages to consumers. These messages can come in the form of direct
marketing, like mail or email marketing, and online marketing, via the Internet, mobile
devices, and satellite television. Data can also be sold for marketing analytics, to predict a
consumers likely behavior. The companies CampaignGrid and Precision Network are
examples of marketing product data brokers. They gather information about Republican

4

"Fact Sheet 41: Data Brokers and Your Privacy." Privacy Rights. Privacy Rights
Clearinghouse, Dec. 2015. Web. 20 Apr. 2016.
5

Federal Trade Commission. "Data Brokers: A Call for Transparency and Accountability."
(n.d.): n. pag. Federal Trade Commission. Federal Trade Commission, May 2014. Web. 17 Apr.
2016.

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and Democrat voters, respectively, and between the two, they have gathered voting
demographic information about approximately 150 million registered voters roughly
80% of the nations registered voters.6 Using this information, these two companies target
consumers with specific political ads of candidates that are tailored to their interests and
demographics. The information is anonymous, as the users name and address are
stripped in lieu of an ID number to protect privacy. However, with the nature of how
personal and private many people consider their political identity to be, this type of
personal targeting raises red flags. A University of Pennsylvania study found that 86% of
surveyed adults did not want political ads tailored to their interests, and 77% would not
return to a website if they know it was sharing information about them with political
advertisers.7
Data brokers who sell risk mitigation products specialize in identity verification.
Their clients include agencies like banks, and assist in confirming the identity of the
banks clientele. In the age of Internet anonymity and fake identities, purchasing data to
confirm identities is very valuable. In the same vein, these companies also sell
information for fraud detection. These clients could include entities like government
agencies, and the data sold can help to verify the reliability or truthfulness of the

Beckett, Lois. "How Companies Have Assembled Political Profiles for Millions of Internet
Users." ProPublica. Pro Publica, Inc., 22 Oct. 2012. Web. 21 Apr. 2016.
7

Turow, Joseph, Michael Delli Carpini, Nora Draper, and Rowan Howard-Williams.
"Americans Roundly Reject Political Advertising At a Time When Political Campaigns Are
Embracing It." (n.d.): n. pag. Annenberg School for Communication. University of Pennsylvania,
July 2012. Web. 18 Apr. 2016.

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information submitted to them.8 An example would be a bank lender (Goldman Sachs,


Wells Fargo, etc.) working with a client to open an account. The lender could use data
broker information to verify that John Smith at 123 Main Street who wants to open an
account with the bank really is who he says he is, thus protecting the lender from
potential risk.9 An example of a verification method would be a data broker that offers a
product indicating how long an email address has existed for, as well as transactions
linked with it. If an email address were very new, it could raise cause for concern.
People search product sellers provide personal information about individuals. This
data is typically intended for use by individual consumers to find lost friends through the
Internet, or to snoop on an individual. The data can also be used for stalking and other
nefarious purposes. Of course, organizations, law enforcement agencies, the media, and
other larger entities can also use this data. The services provided by data brokers selling
people search products are generally online. Consumers usually do not have a legal right
to prevent data brokers from publishing their information, but opting out of such services
is a possibility.10 For example, a data broker could aggregate all of the information
available via a users various public social media, coupled with all other public
information available about that user. With all of the information many of todays social
media users willingly disclose on their profiles, it is easy to see the danger of such data
collection in the wrong hands.

8

Federal Trade Commission. "Data Brokers: A Call for Transparency and Accountability."
(n.d.): n. pag. Federal Trade Commission. Federal Trade Commission, May 2014. Web. 17 Apr
2016.
9

Ibid.

10

Ibid.

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Some of the top data broker firms include Acxiom, DataLogix, Epsilon, and
LexisNexis.11 The average consumer has probably not heard of any of those companies,
nor that they are collecting data about them. This is because the general consumer
population generally does not interact with these companies or do business with them
directly, because the companies do not get this information from the consumer directly.
Although not every data broker company collects every data point, different data brokers
are able combine their resources to create a full picture of a consumers identity or
profile. In fact, much of the data that data brokers collect comes from other data brokers.
The complexity of the industry is a big reason for its lack of transparency.
Data brokers collect their information from a large variety of sources, including
the following: other data brokers, government and public records, such as court filings,
voter registrations, census information, and drivers license records, self reported
information from sweepstakes and surveys postings online, and social media sites, like
Facebook, LinkedIn, and others, which give information like name, age, gender, location,
and other information available on a public profile. Data brokers can also collect data
through less public ways, like purchasing information from retailers or financial
institutions. Data broker company DataLogix gets information from consumer store
loyalty cards, for such stores as Costco, and Smiths. When asked, DataLogix said that it
has information about more than one trillion dollars in consumer spending, spanning
across more than 1400 consumer brands.12

11

"Master List of Data Brokers." Stop Data Mining Me. Winston Law Firm, LLC, 2015. Web.
22 Apr. 2016.
12

Beckett, Lois. "Everything We Know About What Data Brokers Know About
You." ProPublica. Pro Publica Inc., 13 June 2014. Web. 18 Apr. 2016.

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Web browsing data from online advertising networks, retailers, magazines, and
other sites where a log in is required like news, and travel sites are also areas where
information can be gathered. When visiting these sites, small packets of data, called
cookies, are sent by an Internet sever to a browser, and then promptly sent back to the
server each time said server is accessed. Cookies are used to track access to the server,
and identity users on the server.13 Once a cookie has been placed on a consumers web
browser, the cookie remains and continues to track the consumers online trail unless it is
removed. As many people are not aware of cookies, nor are they generally cleared very
often, the cookies can become valuable information gatherers for data brokers.
In this way, it is even possible for data brokers to collect sensitive information
they may not otherwise have access to. Medical data specific to a client, and
conversations with doctors, for example, are both protected interests, but data brokers can
still capture this sensitive medical information. If a user had an online search propensity
for a certain ailment or prescription (meaning the user searched frequently for that
information), or had a history of medical purchases online, a data broker could capture
that information about that users interest in certain health conditions, and be able to draw
inferences from those interests. These inferred data points are referred to as derived data
points, and are also greatly utilized by data brokers.14


13

Beckett, Lois. "How Companies Have Assembled Political Profiles for Millions of Internet
Users." ProPublica. Pro Publica, Inc., 22 Oct. 2012. Web. 21 Apr. 2016.
14

Beckett, Lois. "Everything We Know About What Data Brokers Know About
You." ProPublica. Pro Publica Inc., 13 June 2014. Web. 18 Apr. 2016.

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With the variety of data broker firms, and the variety of data out on the web to be
collected, it is not surprising to imagine that there is a wide range of personal information
collected by data brokers. Much of the information is demographic in nature, and can
include consumer name, address, telephone number, age, gender, income, education, and
occupation. Depending on the specific data broker and what information it is collecting,
the data can also be specialized like purchase history, social media history, hobbies and
interests, medical conditions, and payment methods used.15 In addition to demographic
information, there are also companies that collect lists of people experiencing life event
triggers, like getting married, buying a home, or sending a kid to college.
After the raw demographic information as well as the derived data has been
collected, the information is sold to the clients of data brokers. The data can be sold
individually, but various data points can also be used to place consumers into different
categories, or data segments.16 Combining separate elements to create a list of consumers
who have characteristics in common creates these segments. Men between the ages of 1824, smokers, Spanish speakers, and college students living in Salt Lake City are examples
of segments that data brokers can form. As one could expect, there are countless
segments that consumers can be grouped into, and every consumer can fit into many,
many different segments. With the large number of possible consumer segments, and
how specific they can be, it becomes even more obvious that data brokers are able to

15

Federal Trade Commission. "Protecting Consumer Privacy in an Era of Rapid Change."


(n.d.): n. pag. Federal Trade Commission. Federal Trade Commission, Mar. 2012. Web. 17 Apr.
2016.
16

Federal Trade Commission. "Data Brokers: A Call for Transparency and Accountability."
(n.d.): n. pag. Federal Trade Commission. Federal Trade Commission, May 2014. Web. 17 Apr.
2016.

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paint a detailed picture of each and every individual consumer. In the FTC study, for
example, one of the data brokers had nearly 3000 segments for each consumer. Experian,
a credit-reporting giant, has a marketing services division, which sells lists of names of
expectant parents, and families with newborns, that are updated weekly.17 Data broker
company Epsilon can sell a list of people who read romance novels, or people who
donate to international aid charities.
There is also frequent overlap of consumers in segments, which allows data
brokers to get an even more detailed picture of consumers. For example, data brokers
could analyze the characteristics of consumers that purchased a product, like camping
gear, in the last year, identify consumers who share those characteristics (like age,
location, economic status), and then create a segment called Consumers interested in
buying camping gear. Using methods and models like this, data brokers are able to
predict consumer behavior.18 Not only do data brokers hold massive amounts of
information about consumers, they also anticipate their next move. The information
database that this industry has amassed is both shocking and awesome, but also great
cause for concern.
Considering the magnitude of the industry, both in terms of data collection and
retention, and monetarily, one would expect that the industry would be subjected to legal
scrutiny and regulation to prevent the misuse of such resources. However, this is not the

17

Beckett, Lois. "Everything We Know About What Data Brokers Know About
You." ProPublica. Pro Publica Inc., 13 June 2014. Web. 18 Apr. 2016.
18

Federal Trade Commission. "Data Brokers: A Call for Transparency and Accountability."
(n.d.): n. pag. Federal Trade Commission. Federal Trade Commission, May 2014. Web. 17 Apr.
2016.

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case. There are currently no federal laws requiring data brokers to maintain the privacy of
consumer data, unless the data is used for credit, employment, insurance, or other similar
purposes. The Fair Credit Reporting Act imposes obligations on consumer reporting
agencies, but it only applies to data brokers if they are sharing data for the purposes listed
above. Most data brokers are not CRAs, and are not subject to this act.19 Consumers
generally have no federal right to know what information data brokers have compiled
about them for marketing purposes. They also have no right to correct inaccuracies in the
data, or assumptions made by data brokers. In response to this, The Data Broker
Accountability and Transparency Act was introduced in the senate in March of 2015.
However, as of the writing of this paper, no bill or act has been passed by congress.
One of the problems that stems from the lack of regulation is the potential
inaccuracy of the data. The accuracy can vary significantly, depending on the quality
control procedures of the specific data broker. It is also dependent on the type of data
broker and the business model that the data broker employs. Generally, data brokers who
sell marketing products rely upon the reputation of the sources they get their information
from. The data may not always be accurate and up to date with the user. If a user
switched jobs, but still had a lot of public information available on them about a previous
job they had, it is entirely possibly that the data broker will still see that user at their
previous job. As such, additional steps may be required to keep the information up to
date. Risk mitigation data brokers take multiple steps to assess whether their sources are
providing information that is accurate, because by definition they need accurate

19

InfoLaw Group, LLP. "The Privacy Legal Implications of Big Data: A Primer." Information
Law Group. Information Law Group, 12 Feb. 2013. Web. 20 Apr. 2016.

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information in order to function.20 People search product data brokers generally do not
assess their information for accuracy. They leave it up to the users to determine which
results match the person they are seeking. Think about searching for an acquaintance on
Facebook. Based on what the user knows about the friend they are looking for, like his or
her location, image, education, etc., they would need to discern the differences between
multiple John Does.
There are very obvious problems that arise from data brokers having inaccurate
data about users, and the lack of regulation on the industry. With inaccurate information,
users could easily be incorrectly grouped into one of the data brokers many different
groups of users. A user could inappropriately be targeted for ads for alcoholism, or sex
addiction, for example. This could lead to personal problems should others see this
personal yet incorrect information about a user. Even worse, because not all companies
allow users to correct this data, or even see what data is held about them, users are often
times helpless to fix their situation regarding the data held on them. Depending on how
accurate or inaccurate the data could be, it could also lead to a user inappropriately being
placed on a high-risk list or watch-list, whether the risk is suicide, homicide, terrorism, or
any other dangerous activity. Additionally, if a consumer is subject to a transaction error
due to a risk mitigation error, for example, not only would a consumer be unaware of the
reason for their error, they would be unable to correct it to prevent the error from
reoccurring. With how big the data broker industry is, regardless of how severe the


20

Federal Trade Commission. "Data Brokers: A Call for Transparency and Accountability."
(n.d.): n. pag. Federal Trade Commission. Federal Trade Commission, May 2014. Web. 17 Apr.
2016.

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inaccuracies may be, many users are forced to deal with the repercussions of being
incorrectly grouped by these data brokers.
Another big problem with the lack of regulation of data brokers is the lack of
transparency in the industry. As discussed, the large majority of consumers are unaware
of the existence of data brokers, and the mass of information that they collect. Even those
who are aware of the industry are still left in the dark regarding what information is
collected, who it is specifically collected by, how long it is stored for, where it is sold,
and what purposes it is used for. Even with data brokers who offer opt out services, or
other choices regarding the data they collect, it is not clear about the specifics of what
these policies actually mean.21
Not only is it improper for consumers to be unaware of the information collected
about them, it also poses some potentially scary security risks. Some data brokers store
information indefinitely. Data brokers may argue that keeping data history is necessary to
verify a consumers identity. Other data brokers may not retain the information, as it
would not be relevant to delivering marketing to a consumer. While there are certainly
benefits to retaining the data collected on consumers, the risks involved outweigh those
benefits. As discussed, data brokers have profiles of individuals that are often very
detailed and complete. Thus, these profiles are desirable targets for identity thieves, and
other hackers who can harvest that information for personal gain. If a data broker retains
all of the data collected about a consumer, a hacker could potentially gain a lot of

21

Federal Trade Commission. "Data Brokers: A Call for Transparency and Accountability."
(n.d.): n. pag. Federal Trade Commission. Federal Trade Commission, May 2014. Web. 17 Apr.
2016.

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valuable information about that consumer. While the risk of a hack is a problem for
virtually any software, and any data on any server for an irrelevant amount of time, the
specific concern with the data broker industry is that there is no transparency. Not only is
consumers information potentially at risk, but the consumers also have no idea that their
information is even aggregated to be at risk in the first place.
With the complexity of the industry, and the lack of regulation, it is nearly
impossible to truly track down the answers to the above questions regarding the specifics
of data collection. This lack of transparency is a very glaring problem. The data broker
industry can likely create an accurate and detailed profile of nearly any consumer with
even a remote online presence. These profiles can be analyzed to make inferences about
consumers, and can also be shared with a wide array of clients spanning many different
industries. The biggest problem is that all of this is done behind the scenes, with the
consumer almost completely unaware.
As of 2012, the data broker industry was a $200 billion dollar industry, generating
$150 billion dollars in revenue. Statistically, this can be broken down to the average
email address being worth $89 to a brand. A list of one thousand people in a specific
group is worth approximately $79.22 Though 2016 is only four years later, data has
become exponentially more important, so it is only natural to assume that these numbers
have all increased since then. Still, in the United States alone, there are approximately
319 million people. Obviously not every citizen has an email address, but many have
more than one. By these two statistics alone, it is easy to see how an aggregation of the

22

WebFx Team. "What Are Data Brokers - And What Is Your Data Worth?" Webpage FX.
Webpage FX, 16 Apr. 2015. Web. 21 Apr. 2016.

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data collected by the various firms in the industry worldwide can easily add up to a very
large sum of money.
As has been stated, there is a strong lack of transparency in the industry, and
consumers are largely unaware of the companies themselves, as well as the practices that
they utilize. By comparison, an industry like soccer, which is by far the most popular
sport in the world, has global revenue of $28 billion annually through various leagues,
ticket sales, and other forms of revenue. Along with those annual profits, there are many,
many regulations in every facet of the industry. Soccer worldwide is immensely popular
partly because of the accessibility that it fosters all that is needed is a ball and markings
for goalposts. As such, it is more accessible than the Internet and the data that is
associated with it. Despite the widespread accessibility of soccer, the data broker industry
is still nearly ten times as profitable, and is not regulated.
Because of the number of problems the lack of regulation of the data broker
industry creates, there have been calls to reform the industry in one way or another.
Entities like the FTC have called for legislative action to fix these issues. Companies
within the industry have begun to take steps to self regulate, in an attempt to keep federal
legislation from intervening. However, industries on much smaller scales are subject to
regulation, and as such it is only natural that the data broker industry becomes
legislatively regulated as well.
Primarily, it is imperative that the lack of transparency is fixed. Remedying this
problem will alleviate many of the problems that the industry currently faces. First and
foremost, legislation needs to allow consumers to have access to the data collected about

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them. There is far too much data out there that makes it impossible to justify otherwise.
In the FTC report, the Commission recommended that Congress consider legislation that
requires data brokers to provide consumer access, including sensitive data, at a
reasonable level of detail, and having the ability to opt out of having it shared for
marketing purposes.23 The Commission also recommended four requirements to any
legislation: Enabling consumers to identify which data brokers have information about
them, and where to access such information, requiring brokers to clearly disclose to
consumers not only the information they collect, but what they derive from that
information, requiring brokers to disclose the names and/or categories of their data, and
requiring entities that interact directly with consumers choices about the uses of their
data.24 It also mentioned having protections in place on sensitive information.
In response to the suggested regulations, and speculation about regulation, some
companies have tried to appease lawmakers by becoming more transparent about their
companies, the services they provide, and the data they have collected. Acxiom, for
example, allows interested consumers to contact them to partially see what data has been
collected about him or her. The information given is mostly demographic in nature,
including data points like location, education, economic status, and other similar
information. The data they release, however, is a far cry from the total data that the
broker has collected on an individual. The company also does not disclose where they got
the data from, whom it is sold to, or any other information about the data.

23 Federal Trade Commission. "Data Brokers: A Call for Transparency and Accountability."
(n.d.): n. pag. Federal Trade Commission. Federal Trade Commission, May 2014. Web. 17 Apr.
2016.

24

Ibid.

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Though the information that Acxiom discloses is pretty rudimentary, it could


easily be argued that the information meets the requirement stated by the FTC in their
report of a reasonable level of detail. Ultimately, as with everything regarding privacy,
the circumstances are very subjective. The conditions of a reasonable level of detail
could vary depending on who interprets what those conditions specifically are. While it is
admirable that companies like Acxiom are attempting to show good faith by being more
transparent, the subjectivity regarding privacy and the previously stated complexity of the
data broker industry are two of the primary reasons why enacting specific legislation
regarding regulation is so important.
Personally, I believe that there needs to be more specific regulation than just what
has been suggested in the FTC report, though I do believe that it is a good start.
Obviously, with legislation, it is near impossible to go from no regulation, to acceptable
strong legislation with no in between, and it is also not the job of the FTC to provide
specific legislative suggestions. Still, as mentioned above, the problem with the level of
regulation suggested by the FTC does not solve the issues presented by the current state
of the data broker industry. Data brokers have extensive information on consumers,
through demographic data, derived data, and drawn connections between the habits of
consumers. Simply asking for a reasonable level of detail is not enough. As shown by
the data that Acxiom releases to consumers who inquire, the rabbit hole goes much
further. To the average, unaware consumer, a reasonable level of detail is likely much
less than what would be considered reasonable if a consumer were to be aware of the
amount of data that data brokers have collected.

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I agree that regulation should give consumers access to their data where it
comes from, who it is going to, what purpose it is used for. With this knowledge
available to consumers, they would be able to make more informed decisions regarding
their online presence. They could opt out of services, or even avoid visiting websites that
collect their data all together. Currently, the lack of information is damaging to
consumers and the decisions they make regarding their online privacy. Fixing the opaque
nature of the industry will alleviate many of the current problems with it.
I would also look to specify what determines a reasonable level of detail, in
regards to disclosing information. The word reasonable in and of itself is a subjective
one, as reasonable to one person could very easily not be reasonable to another. In my
opinion, this subjectivity screams ease for loopholes. If consumers at large were aware of
the practices of data brokers, many would change their habits in order to restrict the
information gathered by data brokers. This change in habits would lead to decreased
revenues for data broker companies. As such, I imagine they would prefer legislation
requiring reasonable disclosure, rather than specifics. Ultimately, I would suggest that
the legislation mandate at least 50% disclosure, for starters. As I mentioned, it would be
near impossible to impose strict, all-encompassing legislation immediately. However, I
think that even if the quota were less than 50%, the requirement must be specific;
otherwise it could lead to subverting the law. Ideally, in the future, legislation would
require full disclosure of information, or at least everything asked for by the consumer.
Though discussing the specifics is important, the most important thing is that the
US government regulates the data broker industry in some shape or form. Many members
of congress, as well as consumer groups have been criticizing the industry for this very

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reason. It is time to take action. The data broker industry has more information on each
and every consumer than many can even imagine. It has staggering annual revenues.
Despite this, the industry is still hidden from average, mainstream consumers. Even I was
unaware of it before taking this class, and conducting research on the topic. It is true that
data collection can be beneficial, and can help both consumers and the entities collecting
the data. However, that is no excuse to allow the industry to run rampant as it is currently.
By enacting legislative regulation, the industry is able to continue to do what it says its
main aim is (efficiently assisting consumers), but consumers will be protected from the
potential risks that come from the multi-billion dollar industrys current lack of
regulation. Data collection CAN be helpful to society, but it is imperative to prevent data
collection from owning and controlling society.

Behan 19

Works Cited
Beckett, Lois. "Everything We Know About What Data Brokers Know About
You." ProPublica. Pro Publica Inc., 13 June 2014. Web. 18 Apr. 2016.
Beckett, Lois. "How Companies Have Assembled Political Profiles for Millions of Internet
Users." ProPublica. Pro Publica, Inc., 22 Oct. 2012. Web. 21 Apr. 2016.
"Census History." United States Census Bureau. US Department of Commerce, n.d. Web. 22
Apr. 2016.
"Fact Sheet 41: Data Brokers and Your Privacy." Privacy Rights. Privacy Rights
Clearinghouse, Dec. 2015. Web. 20 Apr. 2016.
Federal Trade Commission. "Data Brokers: A Call for Transparency and Accountability."
(n.d.): n. pag. Federal Trade Commission. Federal Trade Commission, May 2014. Web.
Federal Trade Commission. "Protecting Consumer Privacy in an Era of Rapid Change." (n.d.):
n. pag. Federal Trade Commission. Federal Trade Commission, Mar. 2012. Web. 17 Apr.
2016.
Hoofnagle, Chris Jay, and Jennifer King. "Consumer Information Sharing: Where the Sun Still
Don't Shine."Social Science Research Network. University of California, Berkeley
School of Information, 17 Dec. 2007. Web. 22 Apr. 2016.
InfoLaw Group, LLP. "The Privacy Legal Implications of Big Data: A Primer." Information
Law Group. Information Law Group, 12 Feb. 2013. Web. 20 Apr. 2016.
"Master List of Data Brokers." Stop Data Mining Me. Winston Law Firm, LLC, 2015. Web. 22
Apr. 2016.
Merriam-Webster. "Data." Merriam-Webster. Merriam-Webster, n.d. Web. 15 Apr. 2016.
Podesta, John, Penny Pritzker, Earnest J. Moniz, John Holdren, and Jeffrey Zients, comps. "Big
Data: Seizing Opportunities, Preserving Values." (n.d.): n. pag. White House: Executive
Office of the President. May 2014. Web. 17 Apr. 2016.

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Turow, Joseph, Michael Delli Carpini, Nora Draper, and Rowan Howard-Williams. "Americans
Roundly Reject Political Advertising At a Time When Political Campaigns Are
Embracing It." (n.d.): n. pag. Annenberg School for Communication. University of
Pennsylvania, July 2012. Web. 18 Apr. 2016.
WebFx Team. "What Are Data Brokers - And What Is Your Data Worth?" Webpage FX.
Webpage FX, 16 Apr. 2015. Web. 21 Apr. 2016.
Williams, Lauren C. "Data Brokers Collect And Sell Billions Of Data Points On Nearly Every
American."ThinkProgress. Center for American Progress Action Fund, 28 May 2014.
Web. 23 Apr. 2016.

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