Verizon’s Commitment to Customer Choice

By: Karen Zacharia
Rich Young
T. 202.515.2514
Verizon’s Commitment to Customer Choice, and an Amicable FCC Settlement

Yesterday we reached a settlement to close out an FCC investigation relating to Verizon’s Internet advertising programs.  We committed to continue offering customers the same industry-leading choices they have today about participating in these programs.  To dispel any lingering misunderstanding about a particular advertising “identifier” that we use to make these programs possible, I want to set the record straight.

Advertising helps make possible many of the new online services and products that consumers have come to love.  The Verizon family of companies, for example, offers a wide and growing variety of free services, including The Huffington Post, MapQuest, and our new mobile video service, go90.  Companies delivering ads to consumers use a variety of online and device identifiers so that consumers see advertising for things they may actually be interested in, which benefits everyone. These identifiers range from browser cookies to ad IDs from Apple and Google.  Our programs also use an identifier known as a “Unique Identifier Header” or “UIDH.”

 The UIDH is similar to other advertising identifiers.  It is a randomized string of characters passed along with Internet traffic.  The UIDH is not a “supercookie.”  It’s not a cookie at all.  Cookies are placed and stored on devices.  The UIDH is a piece of data included in the header of certain Internet traffic.  Like other ad identifiers, the UIDH does not contain or transmit any personally identifiable information.  It does not broadcast individuals’ historical web browsing activity to advertisers or others.  The UIDH is simply one among several device identifiers used to place ads that may be of interest to the user of that device.

 In fact, the UIDH is more sensitive to privacy concerns than identifiers used by other Internet companies.  First, Verizon lets customers tell us if they do not want the identifier transmitted at all.  Most of the other leading ad IDs, including those that Google and Apple use, are sent even when customers don’t want to be in the advertising program.  Second, we change the UIDH automatically and frequently for added protection.  The Google and Apple ad IDs must be changed manually.  Third, when used to deliver targeted advertising Verizon keeps the UIDH within the Verizon family of companies.  Others send their identifiers out much more broadly.

In the fall, we proactively told our customers about certain changes we had made to our advertising programs. What we said then remains true today:  Verizon Wireless’ Internet advertising programs are optional and our customers can choose whether they want to participate in those programs or not.  In addition, we previously made clear that if we ever decide in the future to share the UIDH outside Verizon for advertising purposes, we would only do so with companies that agree to strict contractual protections that limit its use to Verizon’s advertising programs.  

In our agreement with the FCC, we also committed that if in the future we transmit the UIDH to third parties to deliver targeted advertising (which we do not do today), we will do so only for those consumers who decided to “opt in” to our advertising programs.  

Last, this settlement does not change what we think the right policy should be in the FCC rulemaking.  A number of trade associations recently submitted a proposed framework for any new broadband privacy rules.  That proposal recommends the FCC adopt guidelines and principles to protect consumer privacy in a way that is consistent with other online privacy laws.  That is the right result.  Any broadband privacy framework adopted by the FCC should be flexible enough to permit carriers to innovate and compete while providing customers the information they need to make privacy-related decisions.

Verizon Chief Privacy Officer