Ban on Surveillance Advertising?: Networked Harms of Data-Driven Advertising and the Need to Bridge Policy Silos in the United States

Analyzing public comments submitted to the US Federal Trade Commission (FTC) in response to a proposed ban on “surveillance advertising” or online behavioral advertising (OBA), this study examines how sociopolitical actors negotiate OBA regulation. The study finds that civil society groups and industry associations tend to adopt contrasting strategies, either bridging or siloing policy areas of privacy, antitrust, and antidiscrimination. These differences largely stem from divergent understandings of the roles of non-Big-Tech businesses and whether OBA-related harms are interconnected. The study highlights the importance of bridging policy silos to better account for the datafication underpinning OBA and its networked harms.