In response to the Federal Trade Commission’s (FTC) request for comments in its spring privacy workshop on mobile technology (Project P145401), the Direct Marketing Association (DMA) has submitted comments expressing its support of self-regulation of mobile marketing practices.

In its letter to the FTC, DMA states: “The DMA supports the self-regulation of mobile marketing practices, a rapidly changing industry still at the earliest stages of development. Self-regulation strikes the appropriate balance of protecting entrepreneurs, encouraging innovation, and promoting economic growth while also ensuring that important considerations about privacy and security are addressed in an effective, yet flexible manner.”

Mobile marketing, as does all data-driven marketing, has tremendous value for consumers.   DMA supports responsible practices and self-regulation principles, and in fact, recently released the 2014 DMA Ethical Business Gudelines to include updated mobile marketing guidance.   For more than forty years, DMA has successfully set and enforced standards for responsible marketing for our industry.

“Consumers already are receiving benefits from mobile marketing technology and stand to gain countless more through the growth and innovation in the mobile marketing technology space. Developments in mobile marketing technology have enabled consumers to transform their mobile phones into powerful tools for education, shopping, gaming, socializing, and many other functions,” the letter to the FTC states.  “As more consumers engage mobile technology, they expect businesses to be able to seamlessly migrate to the mobile space and deliver goods and services through mobile devices. Mobile marketing technology provides the tools for businesses to exceed these expectations by delivering better value and more relevant results than before.

“The DMA cautions against imposing restrictions based on speculative harms that could unduly
burden competition for in-store and digital commerce.   Absent evidence of concrete harm to consumers, the approach to privacy protection must protect  consumer value and the culture of innovation,” the letter reads.

DMA states that industry should be encouraged to develop clear but flexible principles that are enforced through self-regulation, allowing for adaptation to new technologies and encouraging innovation and promoting economic growth.  “We are witnessing a mobile marketing industry that is still in its infancy,” DMA states in the letter.  “At this early stage, regulators should encourage marketplace incentives and industry self-regulation to address issues related to privacy rather than prescribing regulations.”

The full text of the letter is available here.



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