But these days, the position that behavioral targeting can pose a threat regardless of whether it causes a concrete, quantifiable harm seems to be gaining favor in Washington.

"Privacy is an important value in and of itself," FTC consumer protection chief David Vladeck said today at a privacy workshop at NYU Law School. He said focusing solely on tangible harm is too limited, given the vast array of non-economic harms that can result from online targeting. Such as? He listed the possibilities: reputational harm, the fear that private information will be exposed, and the prospect that personal data will be used in unexpected ways, among others.

While Vladeck said he believes behavioral advertising offers benefits in the form of more relevant ads, he was very clear that companies should do a better job of informing Web users about tracking.

What would he like to see? Vladeck proposed that targeted ads could include links saying, "Why did I get this ad?" that would take users to a page explaining behavioral advertising.

Vladeck also suggested that prior notions that personally identifiable information is limited to names, addresses, social security numbers and the like are outdated. For instance, he said, information that might seem "anonymous" in itself can be combined with other "anonymous" information to identify someone.

Referencing Latanya Sweeney's much-publicized study showing that 87% of Americans can be identified by gender combined with ZIP code and birthdate, Vladeck said notions of personal information should keep up with technology. "We can't sell an eight-track policy in an iPod world," he said.

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