Nine separate Privacy Shield complaints against Facebook
I have just filed nine separate (US-CH) Privacy Shield complaints against Facebook with the Swiss data protection authority.
The requests are:
- for data points used to target ads;
- on Lookalike Audiences for political targeting (no doubt this is illegal);
- for access to Facebook Pixel data;
- for access to Facebook Custom Audiences data;
- for access to Facebook Lookalike Audiences data;
- for access to additional information regarding “Advertisers with my contact information”;
- for daily access to information regarding “Advertisers with my contact information”;
- for full list of advertisers who ever had my contact information;
- for further information on means available to advertisers to track me on Facebook.
The links above point to my original exchange with Facebook. You can see the date of each post there.
These then became complaints with the Safe Harbor arbitrator/Privacy Shield mediator, TRUSTe, which has refused to act on these.
These TRUSTe complaints were met, after exchanges over several months on the substance of the request, by a two-sided decision that Safe Harbor or Privacy Shield protections should not apply to the requested data.
Note that my opinion on jurisdiction or relevance of Privacy Shield/Safe Harbor was never asked, that TRUSTe is supposed to be an independent mediator/arbitrator, and that it consulted privately with Facebook prior to dismissing my complaint, in violation of its own rules of procedure (this is itself a basis for a FTC complaint against the arbitrator, for deceptive commercial practices…).
Paul-Olivier Dehaye is co-founder of PersonalData.IO, a startup helping individuals regain control of their personal data, through innovative products built around the GDPR. PersonalData.IO also offers compliance solutions, business innovation and consulting services to companies, as well as expert advice to educators, regulators and journalists.
