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FAST-TRACKING THE TRACKERS: APPREHENDING AND COMPREHENDING ADVERTISING TRACKING PRACTICES IN EDTECH

The Common Sense Privacy Program has initiated a deeper look into advertising tracking practices in educational technology (Edtech). This paper will as an introduction begin by covering advertising tracking law and policy as it exists, including GDPR, Federal Trade Commission (FTC) jurisdiction, constitutional foundations, and federal legislation, as well as inroads states have made to protect consumers. The section of this paper covering types of advertising will further expose the difficulties of compliance with and enforcement of advertising law as it pertains to tracking. Following, this paper will explain the development methodology of the Privacy Program’s latest project to develop a tool that can evaluate over 3,000 Edtech-related company URLs to detect whether they use ad trackers. This section will describe the tools used, how we automated the detection process of third-party URLs on these 3,000 domains, and how to categorize which trackers would be considered advertising/tracking related uses based on deference to existing publicly available known advertising and tracker lists. Next, this paper describes the results of this research, including the technical challenges that may be encountered, planned analysis of the data gathered, and a summary of the industry’s gaps in transparency. Finally, this paper concludes with a hypothesis about the state of the ad tracker industry as it intersects with Edtech used by consumers and educators. This final section will address recommendations for each stakeholder group involved in the process, from developers interested in privacy by design, to regulators, educators, and consumers who interact with their designs.