Google has offered the Australian Competition and Consumer Commission (ACCC) a number of ideas on how best to progress with policy in the digital advertising area, saying a “collaborative” approach would offer the most benefit to customers and Australian services.
” Google is successful when our partners do– so we have a strong incentive to ensure a healthy digital marketing community,” a blog post penned by Google Australia’s marketing director Barney Pierce stated.
The competitors watchdog is currently probing the marketing technology (advertisement tech) sector, focusing its efforts, once again, on the search giant, with the ACCC interested in “Google’s industry-leading position”.
In response to the ACCC beginning the questions, Google argued advertisement tech is a competitive market with low barriers to entry, which it’s merely among the lots of companies using such a service.
The search engine giant stated it develops AU$32 billion in advantages every year for organizations and content creators in Australia through its marketing platforms.
In its 68- page submission [PDF] to the query, Google said the ACCC’s Interim Report presented an incomplete view of the digital advertising industry.
” Focussing only on web-based open screen advertising leads to a misleading view of market dynamics,” it stated.
” Any regulatory intervention should not lower the development and competition that has actually driven so many benefits”.
Google stated ad tech has been marked by consistent innovation, driven by the progressing needs of marketers, publishers, and customers. This continuous development, Google claimed, significantly changes the ad tech landscape every 2 to 3 years.
” The dynamism of the advertisement tech community integrated with these differing interests indicates that it will be extremely tough to anticipate all of the consequences of any intervention,” it said. “In the face of these issues, regulation is likely to produce unanticipated disadvantages and disturbances.”.
Google has actually asked the ACCC to also consider the ramifications for customer personal privacy when designing proposals.
” Several of the ACCC’s proposals will impact consumer personal privacy,” it said. “This extends beyond information portability and interoperability procedures (which the ACCC has acknowledged will depend upon the underlying privacy regulatory framework presently under review).”.
It also stated the ACCC’s propositions around information separation procedures, such as through data silos or purpose limitation requirements, may overlap with the problems being thought about in the Privacy Act Review. Similarly, Google said the guard dog’s proposals to increase transparency and address concerns of supply chain opacity may conflict with the privacy problems being considered in the review.
” We for that reason think it is vital that the ACCC speak with the Attorney-General’s Department, the OAIC, and other relevant stakeholders (including privacy advocacy groups such as the Australian Personal Privacy Foundation) for the remainder of the Inquiry to think about the privacy implications of the ACCC’s propositions,” it stated.
Google in its submission also supplied discuss how the ACCC need to think about procedures for enhancing data portability and interoperability.
” Our company believe the ACCC’s objectives are best accomplished by information mobility determines that are industry-led and industry-wide and where the user is in control,” Google said. “To protect consumer privacy and promote involvement and competition, such procedures must just use to data controlled by the user.”.
Information portability steps ought to not use to data that the user does not manage, Google said, providing examples such as data about a consumer’s activity on a website where their advertisements are displayed.
Google included that data portability ought to not encompass information that a service provider creates by utilizing a consumer’s information– presumed information– such as a user profile developed by analysis of the information collected.
On the problem of conflict of interest and self-preferences, Google stated it thinks the current Competitors and Customer Act 2010 provisions suffice for resolving prospective competitors issues that might occur from vertical combination in the advertisement tech chain.
In addition, Google labelled the interim report as having a narrow focus, specifying it omits essential competitors dynamics that constrain Google’s advertisement tech organization.
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