In comments submitted to the Federal Trade Commission today, SIIA highlighted the innovative and evolutionary nature of cross-device linking, which is already an integral part of the Internet ecosystem that has become more seamless for users while operating with significant security capabilities.  The comments identified the following three areas as driving increased deployment of device-linking, which are substantially beneficial to users, as well as the entities providing the services:

1. Enhanced digital services offerings and customer analytics—The ability to match a user across their myriad connected devices is a critical function to provide users with seamless access to individually-tailored content and services, whether accessed on a computer, smartphone, tablet, smart TV, or another connected device.
2. Advertising revenue for digital content—Digital advertising has long been an engine of growth for the digital economy and a crucial source of revenue for many Internet publishers and media companies who offer their information content for little or no cost to consumers. As advertising revenue continues to shift from print and other media formats to digital media, the ability to more effectively monetize digital content is expected to further increase.
3. Authentication and security—It was a lot easier to protect customer transactions and enterprise data and services when employees and customers only accessed business systems and web sites through a single computer or workstation. However, the increasing number of devices and native mobile applications and mobile-Web applications often calls for strong authentication of users across devices to prevent fraud and improve compliance across each users range devices.

SIIA recognizes that inadequate transparency regarding the practices of entities to match consumers with their personal devices, and to possibly collect and compile significant behavioral information from consumers, could no doubt foster substantial confusion and distrust in the connected environment.  Therefore, SIIA concurs with the consensus at the recent FTC Workshop that effective transparency and control are a priority dependent on the context in which the cross-device linking or tracking occurs. Of course, for transparency and control to be effective, it must be implemented efficiently and flexibly to balance the abilities of publishers, advertisers and other entities.

Given the rapid technological evolution taking place with respect to device-matching technology, SIIA urges the FTC and policymakers to refrain from seeking new legislation or regulations to establish rigid transparency and control requirements on current or evolving device matching practices.  Alternatively, policymakers should continue to encourage broad adoption of voluntary industry best-practices that provide sufficient flexibility for diverse and evolving practices.

David LeDuc is Senior Director, Public Policy at SIIA. He focuses on e-commerce, privacy, cyber security, cloud computing, open standards, e-government and information policy. Follow the SIIA public policy team on Twitter at @SIIAPolicy.