• by Wendy Davis , Staff Writer @wendyndavis, May 2, 2011

The Federal Trade Commission should order Google to stop stating in its privacy policy that its behavioral advertising program doesn't collect personal information, privacy group Center for Digital Democracy argues in a new FTC filing.

"As Google undoubtedly knows, in today's digital marketing ecosystem, one doesn't have to know someone's street address to identify his or her behavior (let alone location)," the CDD says. The group adds that Google's platform, which stores information about users on cookies, allows for targeting that's so detailed that it shouldn't be characterized as anonymous.

"Google uses cookies to target a user more precisely with digital marketing, in order, in its own words, to 'convert' him or her to the goals of the marketer. Consequently, the commission should require Google to revise its policies to reflect the inherently personal nature of cookies and related data targeting and collection applications."

That recommendation concerns just one aspect of Google's privacy policy that the CDD says should be revised. The group also is calling for Google to give consumers more information about a broad array of outside companies it works with to deliver online ads. Additionally, the CDD says that Google should obtain consumers' opt-in consent before deploying "yield management and optimization" technology.

The CDD's comments were filed in response to the Google's Buzz settlement agreement. The FTC last month said Google had agreed to settle charges that it engaged in a deceptive practice by launching the social networking service Buzz on an opt-out basis.

When Google launched Buzz, the company attempted to create social networks out of people's Gmail contacts. The problem was, Google set up the service so that it revealed some of the names of users' email contacts by default. Those disclosures violated Google's privacy policy, according to the FTC and consumer advocates.

The tentative settlement calls for Google to create a comprehensive privacy policy. Additionally, the company promised that in the future, it will obtain users' opt-in consent before using their information in new ways.

The FTC is accepting comments through today. A host of groups are expected to weigh in but, as of Monday afternoon, the agency had posted around two dozen comments. One notable response came from New Zealand privacy commissioner Marie Shroff, who said the settlement "represents an approach that is well matched to the privacy risks of the business model adopted by this company."

Another came from students in a 2010 University of West Alabama computer ethics class. Their teacher, Richard Day, wrote in to say that his students wanted to weigh in with the suggestion that "Google be required to pay a substantial penalty for any future privacy violation."