The Federal Trade Commission (“FTC”) has requested public comments on the prevalence and potential regulation of commercial surveillance practices related to how companies collect, aggregate, protect, use, analyze, and retain consumer data, as well as transfer, share, sell, or otherwise monetize that data in ways that are unfair or deceptive.

The Athena Coalition is submitting comments about the unfair and deceptive practices resulting from Amazon’s unprecedented misuse of surveillance and algorithmic manipulation across its marketplace, within homes and on street sidewalks, within workplaces, and among its platform-based workforce. Athena is a coalition of over fifty local- and national- organizations that include: worker groups, technology policy and anti-monopoly advocates, and economic, environmental, and racial justice organizations.

Amazon serves as an example of how unregulated surveillance gives corporations too much power over people, particularly when those corporations have monopoly control over particular sectors, engage in mega-mergers, and have unparalleled surveillance reach across domains.

For the purposes of these comments we focus on the unique harms that come when mega-corporations, like Amazon, use their unprecedented scale and reach to consolidate power and control in ways that impact: consumer and business choices when shopping online and on Main Street; privacy in our homes, neighborhoods, and in the workplace; entrepreneurs’ ability to start new businesses that will thrive; and, people’s ability to work. We believe it is especially important for the FTC to consider cases like Amazon, a sprawling and powerful corporation that uses surveillance technology to further grow and maintain its dominance across several markets: ecommerce, doorbell cameras, cloud services, virtual/voice assistants, home speakers, logistics, warehousing, and delivery.

Amazon’s misuse of surveillance technology and data demonstrates the scope of these dangers across domains, including: threatening people’s ability to freely speak out and organize in the workplace and in the public sphere through the expansion of pervasive surveillance; radically decreasing privacy in homes, neighborhoods, and online in nonconsensual ways; rigging the rules on its marketplace in ways that harm small businesses and manipulate consumer behavior; and undermining safety, wellbeing, and fairness in the workplace.

We advocate for commercial surveillance rules that protect everyone, including small businesses and working people, from unfair and deceptive practices now and in the future – and we advocate for rulemaking that considers the relationship between privacy harms, behavioral manipulation, the scale and reach of surveillance, anticompetitive practices, and mergers.

Read the full comments here.