Monday, January 18, 2016

Guest Post: Our Government Online – Have The Risks of Online Advertising for Consumers Been Fully Considered?

By: Mark Dobosz
January 15, 2016

In a March 2014 Forbes Magazine article, “5 reasons your Business Should Use Google Ad Words” author John Rampton states, “By using the right keywords for your target audience, you’re already ahead because you’re reaching people who have an interest in your product or service.”

So why would a government regulator feel the need to drum up more business for a service that is clearly and readily available to consumers? Is there not enough interest they (the consumer) have in utilizing the service?  And has the government regulator fully calculated and balanced the risks and hazards of the online advertising environment based on solid research?

An online posting today by Ballard Spahr (“CFPB Using Google Ads To Solicit Consumer Complaints”) points out the following  - “In an effort to publicize its online complaint system and bring in more complaints, the CFPB is now soliciting complaints through Internet advertising.”

In May 2014, the Permanent Subcommittee on Investigations of the U.S. Senate

Homeland Security and Governmental Affairs Committee issued a report – “Online Advertising and Hidden Hazards to Consumer Security and Data Privacy.”

The Sub-Committee’s report cited the following:

“Although consumers are becoming increasingly vigilant about safeguarding the information they share on the Internet, many are less informed about the plethora of information created about them by online companies as they travel the Internet. A consumer may be aware; for example, that a search engine provider may use the search terms the consumer enters in order to select an advertisement targeted to his interests. Consumers are less aware, however, of the true scale of the data being collected about their online activity. A visit to an online news site may trigger interactions with hundreds of other parties that may be collecting information on the consumer as he travels the web. The Subcommittee found, for example, a trip to a popular tabloid news website triggered a user interaction with some 352 other web servers as well. Many of those interactions were benign; some of those third parties, however, may have been using cookies or other technology to compile data on the consumer. The sheer volume of such activity makes it difficult for even the most vigilant consumer to control the data being collected or protect against its malicious use.

Furthermore, the growth of online advertising has brought with it a rise in cybercriminals attempting to seek out and exploit weaknesses in the ecosystem and locate new potential victims. Many consumers are unaware that mainstream websites are becoming frequent avenues for cybercriminals seeking to infect a consumer’s computer with advertisement based malware, or “malvertising.” Some estimates state that malvertising has increased over 200% in 2013 to over 209,000 incidents generating over 12.4 billion malicious ad impressions.4 According to a recent study by the security firm Symantec, more than half of Internet website publishers have suffered a malware attack through a malicious advertisement. The Subcommittee seeks to highlight this specific aspect of online security. The Internet as a whole, as well as all the consumers who visit mainstream websites, is vulnerable to the growing number of malware attacks through online advertising. While there are many other significant vulnerabilities on the Internet, malware attacks delivered through online advertising are a real and growing problem.”


Permanent Subcommittee on Investigations of the U.S. Senate

Homeland Security and Governmental Affairs Committee

All of us know that maintaining effective information security programs — and overseeing cyber security – especially among supervised federal regulators (i.e. the CFPB) who routinely handle personal information of consumers is paramount to their role and integrity of purpose. 

However, it is public knowledge from reports released in October 2015 by the CFPB’s’ inspector general, that cyber security remains one of the agencies top management challenges.

Protecting consumers is the ultimate goal of all players in the credit ecosystem – industry and regulators. Nether side can’t afford to not be hyper-vigilant in protecting consumer data in the world of cyberspace crime through online interactions.
Industry has already been tasked with multiple requirements to insure protection and confidentiality at an extremely high cost – while simultaneously being limited in their communication and data collection methods.
Federal regulators should be held to the same standards and methods of protection of consumer data.  Engaging in practices like online advertising that have been proven to present great risks to consumers – without further in-depth research and the costly prevention systems can be irresponsible. Agencies that have been cited for having challenges to managing their cyber security programs should take note.
An ecosystem only functions optimally when all the components are operating in unison and sync with each other.

About the Author:  Mark Dobosz currently serves as the Executive Director for NARCA – The National Creditors Bar Association. Mark is a one of NARCA’s speakers on many of the creditors rights issues impacting NARCA members. 

The National Creditors Bar Association (NARCA) is a trade association dedicated to creditors rights attorneys. NARCA's values are: Professional, Ethical, Responsible

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