Peter A Clarke

After a false start the ABC is installing mandatory iview login requirements for its television services.  This has raised the hackles of privacy advocates.  In February the Conversation fired up with Mandatory logins for ABC iview could open an intimate window onto your life.   Most recently, as in earlier this week Malcolm Crompton, a former privacy commissioner, has claimed that this will stymie debate and free expression of ideas.  It has also attracted the ire in itwire with ABC appears to be hell-bent on compulsory iview logins and ABC is urged to ditch hated feature on its streaming platform iview – but the public broadcaster is adamant it WILL roll out this week.   Vanessa Teague has produced a very effective youtube video setting out the problems with data sharing (https://www.youtube.com/watch?v=20bqzIoB-Fw).   The problem is that while Vanessa’s post is very thoughtful and persuasive it has been read by 491 views as of today’s date.  It has been the subject of chatter amongst privacy advocates but not much more than that.  That makes it completely ineffective.  Innovation Australia in Last ditch call to stop ABC mandatory login highlights the problem, that a last ditch effort is usually a forlorn hope.  It provides:

Privacy and security experts have called on the ABC to halt its switch to mandatory user accounts at the eleventh hour, warning that the public broadcaster has failed to justify the increased risks of tracking users and sharing data with US tech giants.

Letters to ABC management from the Australian Privacy Foundation and a former privacy commissioner released this week call for the ABC to reconsider the decision, saying the purported benefits are not proportional to the risks they introduce, while a leading cybersecurity expert warned data is still being collected even though users opt-out of tracking.

The ABC intends to make the switch to mandatory user accounts for its iview video-on-demand service on Tuesday, claiming it will allow more personalisation features that it says users want, and that tracking audiences and their viewing habits is now commonplace.

InnovationAus understands the latest calls to reconsider have not swayed the ABC and it intends to press ahead with the switch it had initially hoped to make last July.

The move will force millions of iview users to register an account to keep watching, and has been described as “unnecessary, intrusive, inconsistent with community expectations” by the Australian Privacy Foundation (APF).

The APF sent detailed concerns to ABC chair Ita Buttrose at the start of the month. Ms Buttrose responded in writing last week but failed to justify the move, according to the privacy foundation.

“Thanks again for taking the time to reply in detail to our concerns. However, despite the benefit of some clarifications, the fundamental weakness of the case for mandatory registration seems unchanged,” APF chairman David Vaile and board member Juanita Fernando wrote in response.

The advocates now want the public broadcaster to abandon mandatory logins or at the very least least conduct community consultation and retain unregistered success.

Currently, iview registration requires personal details like name, email, location, date of birth and gender. Viewing habits are tracked and shared with Facebook, Google via an intermediary company for advertising on the US giants’ platforms.

Iview users can opt-out of the data sharing with third parties, but it is on by default and requires a manual change in account settings, while data experts contend the information may still be being collected and shared.

The public broadcaster insists it is moving with the times of digital media and the accounts are needed to offer features like watchlists, resumption across devices and personalised recommendations.

Former Australian Privacy Commissioner Malcolm Crompton also wrote to ABC management, urging managing director David Anderson to reconsider in June last year.

Mr Crompton questioned whether users are being adequately informed about data collection, use, and sharing, and warned some young, elderly or others with less familiarity with technology could be locked out.

He also questioned whether personalisation is a “desirable goal” for a national public broadcaster.

“If ABC viewers want a ‘personalised experience’, they would opt in. Opt-in data collection, data sharing and personalisation, if done transparently, would be a choice for those who want it,” Mr Crompton wrote.

“For me and others, the very last thing I want is ‘personalisation’ which becomes a set of blinkers that removes peripheral vision.”

The former privacy commissioner was joined by Thinking Cybersecurity chief executive Vanessa Teague in criticising the move on Monday. She warned the ABC is exchanging information about users with digital platforms including Facebook and Google without consent and even when account settings are set to opt out of personalisation.

There is no option to opt out of the underlying data collection and sharing, according to Professor Teague, an eminent cryptography and data sharing expert.

“We own this broadcaster and already paid for this material. Every Australian should be able to explore its excellent content and challenging topics without those explorations being tracked, recorded, and disclosed to companies that fuel global misinformation,” Professor Teague said.

The Australian Privacy Foundation has been quite active in this space.  But ineffective.  It wrote a press release on 23 February 2022 with Mandatory logins for ABC iview could open an intimate window onto your life, On 2 March it a (over) long open letter on 2 March 2022 stating:

This open letter is to raise our concerns and objections to proposals for mandatory registration for Australians to use ABC online services from March 2022. The proposal is unnecessary, intrusive, inconsistent with community expectations of protection from online tracking, a potential security or safety threat, and breaches the right not to have to identify yourself offered by Australian Privacy Principle 2 (APP 2). It should not go ahead.
1. While the case for offering ABC iView users the choice of an optional voluntary online account with some form of registration may be more straightforward, a key question is what specific technical or other audience/user need can only be met by a mandatory involuntary registration?
2. It is not essential for audience members to be required to register with the ABC for the broadcaster to analyse usage figures to understand the content, features and kinds of programmes people like. The ABC’s usage figures illustrate this already.
3. The information collected by an iView account does not necessarily enable analysis of who in a household is watching what program, simply that someone in that household is watching. So the ABC’s claim that account-holder information collected and used by these mandatory accounts is necessary to provide a granular view of watcher engagement for programming analysis is not persuasive, and does not demonstrate this intrusion is necessity for improving ABC services for all Australians.
4. Anyone wanting the ‘continuation’ programme function, or any other claimed benefits of an ABC account, should be able to voluntarily register if they wish. Others who do not want the claimed benefits, or who do not wish to expose their (or their household’s) online activity to more surveillance, should be able to choose not to
register without being excluded from the service. (As taxpayers they already fund it).
5. The ABC says it conducted Video On Demand research last year with a ‘nationally representative sample’ of over 1500 people. 95% of ABC iView users were said to have expressed a desire for new and improved digital features, and this is said to justify the proposal. We would be obliged if you could point us to where the research
methodology which describes these desirable digital features, the framing of thequestions, and the responses is publicly available.
6. On behalf of the many Australians who value their privacy and information security, and who may thus be obliged to use anonymous or spurious information to register foran unwanted ABC iView account if it becomes mandatory, we seek to understand if there are any specific guarantees that information and metadata supplied by their software and Internet activity (such as persistent IP addresses, device fingerprinting, and the like) will not be compounded by linkage to the new non-optional account. For instance, will Google, Amazon, Facebook/Meta or other foreign commercialonline surveillance operators be able to exploit ABC account information or behavioural data traces to a dd to their own existing psychographic profiling information about users of online services? We would appreciate any technical detailson work done to investigate or address this risk.
7. The so-called “opt-out” feature of the proposed mandatory iView account apparentlyrequires a user to first accept the ABC unilaterally creating an account – one already defaulting to tracking and online behaviour data collection. After conceding the creation of an account they do not want, unwilling account holders must then navigate from the “Manage > ABC account” drop-down menu to many different text boxes, each of which must be manually changed (including Login Details, Data and Privacy). As with purported ‘privacy options’ in systems like Facebook, “opting-out” of iView registration involves a cumbersome and user-hostile process, one apparently designed to be tedious enough that many users will be ‘nudged’ to give up and not bother. This “opt-out” process is, in our view, unusable, rather than a credible or respectful mitigation measure for the privacy intrusion the Corporation is proposing. We would be happy to help workshop alternative, more respectful “opt-in” models
that could avoid this sort of passive-aggressive user experience. (The simplest is not to require a mandatory account, and not to create one unless it is the user’s choice.)
8. In any case, the notion of “Opt-out” account settings seems like an oxymoron (an account that is a non-account or a semi-account) because it means that mandatory data will still be collected and potentially used by the ABC (whether for possible disclosure to third party marketers or some other purpose). It is reminiscent of
commercial ‘opt out’ online tracking schemes, which require users not wanting to be tracked by cookies to accept a tracking cookie to mark their choice to opt out, with a user-opaque back end and no way to tell what happened to the retained personal information thereafter.
9. We understand that the Privacy Impact Assessment (PIA), a useful process if conducted openly and consultatively by a trustworthy independent expert, was conducted “in-house”. This flawed approach lacks independence and transparency, compromising the process’s rigour. The usual explanation for this sort of PIA is a
prior commitment to implement the plan [a mandatory registration system] anyway, regardless of issues like intrusiveness, threats to privacy, potential to undermine trust, or lack of justification – at worst, a PIA as a box-ticking compliance exercise, rather than as a credible, open investigation of potential impacts and an opportunity to explore alternative ways to achieve necessary effects.
10. Australian Privacy Principle APP 2.1 in Privacy Act 1988 (Cth) provides that ‘individuals must have the option of not identifying themselves, or of using a pseudonym, when dealing with an APP entity [such as the ABC] in relation to a  particular matter’. There are only two exceptions:
? APP 2.2(a): where ‘the APP entity is required or authorised by or under an Australian law, or a court/tribunal order, to deal with individuals who have identified themselves’, or
? APP 2.2(b): where ‘it is impracticable for the APP entity to deal with individuals who have not identified themselves or used a pseudonym’. Neither exception applies to the ABC’s proposal for mandatory registration, which amounts to mandatory identification. This thus contravenes every Australian’s right to choose not to identify themselves except in limited, exceptional circumstances.
11. If this proposal is put in place, what guarantee is there that other services will not be subjected to similar unnecessary intrusions, denying free and open access to public information services offered by the ABC?
12. What will occur when someone without a functioning ABC account tries to access the national broadcaster’s services? Will they be excluded from access? Not only is a mandatory registration scheme unnecessary and privacy intrusive, it also potentially creates barriers to access for certain sorts of people or in certain circumstances. While young, urban ‘digital native’ creatives with reliable internet access, and without the impediments of disability, age, or cognitive, cultural or other adverse circumstances, may treat this as a trivial matter, the ABC’s role as provider of essential community service information may be compromised by such a mandatory registration barrier, since it may have unexpected adverse consequences at certain times: think of people stuck at night on a rooftop in a flood, those with physical or cognitive difficulties, or with unreliable connectivity in some other crisis. The default should be the ABC’s online services should ‘just work’ at a basic level regardless of whether you may have forgotten your login, lost your device, suffer something else that makes registration difficult, be running low on battery or signal, or be hindered by some other challenge.
13. With this radical and unnecessary departure from the appropriate behaviour citizens have come to expect of a public service broadcaster – it creates a non-voluntary online identification scheme of the kind typically justified as supporting the sale of mass psychographic profiling ‘insights’ to a platform’s advertisers – can the public be expected not to suspect the proponents are doing the government’s bidding and preparing the ABC for privatisation and commercial exploitation? Taken together these issues suggest the mandatory registration scheme, having been prototyped and considered, should now be set aside

The ABC responded on 8 March 2022 states:

Thank you for taking the time to write to me about your concerns in relation to ABC iview.
As you can imagine, the ABC team has spent a lot of time considering the issues which you have identified. There are complex public policy considerations which the ABC has taken into account. The ABC has aimed to strike the right balance between privacy considerations and serving our digital media audience, including by ensuring that we collect only a small amount of personal information to inform content decisions.
It is important to the ABC to ensure that leaders in the privacy community like yourself have confidence in the measures we take. Your views will no doubt influence others and that influence can have an important impact on public policy outcomes.
We are keen to make sure that Australians receive an informed, balanced perspective in relation to why Login to Watch is being introduced for ABC iview, and that people are not unduly cautious about logging in. Any unfounded concerns could have negative public interest outcomes, such as lower login rate, and consequently people choosing to go to other, less reliable, sources of information with lower levels of privacy protection.
I would like to respond to the points made in your letter.
Points 1 – 3
Login to Watch allows the ABC to gain a better understanding of how audiences are engaging with ABC content, and therefore contributes to our understanding of how best to deliver on our Charter.
The minimal level of invasiveness associated with an individual creating an account and providing a small amount of information about themselves, being name or nick name, year of birth, location and gender (with prefer not to say as an option) is outweighed by the public benefit of better serving audiences, including by allowing for better informed program commissioning and licensing decisions. In contrast, I refer you to the bottom of page 11 in the ABC’s draft Privacy Impact Assessment (PIA) for a brief description of the deficiencies in modelled demographic data, which is informed by broadcast measurement.

Point 4
A vast majority of Australians surveyed by the ABC desire Video On Demand (VOD) features that can only be made available by logging into an account, such as ‘continue watching’ across devices, recommendations, and profiles. Our research indicates that if we do not require people to log in to access those features, then they will not take the time to do so, and those features will not be available to them. In the long term, this would be likely to lead to a loss of viewers, and it would also mean that the value to Australians from the investments the ABC makes in quality content would be diminished.
The cost of this to the Australian community would be real. It is not in the Australian public interest for audiences to migrate to platforms that hold little in the way of quality Australian content, offer limited privacy protection, and promote misinformation and filter bubbles for the sake of profit, while the ABC becomes increasingly unappealing and irrelevant to audiences by failing to deliver a viewing experience that audiences have come to expect. I direct you to pages 9-11 of the draft PIA for discussion around why providing a voluntary login function was not deemed to be in the public benefit.
Point 5
Where appropriate, the ABC releases relevant data and research. Any further release of audience research will be made public on the standard ABC website.
Point 6
The ABC does not share user behaviour linked to account information with third parties. For example, see the information about Encrypted Email Promotion Requests on pages 39-43 of the draft PIA, where Facebook and Google do not receive any data about behaviour on ABC platforms linked to an account.
Point 7 -8
The ABC does not offer opt-out of an account. Once an account is created, the ABC offers an opt-out of “Promotions on Digital Platforms” and “Personalised Recommendations”. It is not a complicated process. Users go to their Account Settings and opt out via the Data and Privacy section. The ABC will delete a user account upon request.
Point 9
The draft PIA was a result of extensive consideration and information gathering from the Australian public, public broadcasters internationally and consultation with the OAIC and others.
Point 10
Individuals may create an account by way of an email that does not include identifying information. The ABC’s position on this accords with the Australian Privacy Principles Guidelines, published by the OAIC. The draft PIA expressly addresses the pseudonymity issue on pages 29– 31.

Point 11
There are no current plans to make a login requirement necessary for other ABC digital products. The login requirement has been introduced for the VOD component of ABC iview so that the ABC can provide a modern service with the features Australians expect, and also to improve the ABC’s capacity to provide and make discoverable, quality content that reflects all Australians.
Point 12
All broadcast services and other online services provided by the ABC, including the broader suite of ABC apps and websites, are available without logging in. Viewers will remain able to access all live ABC broadcast streams on ABC iview on web, including web accessed by way of mobile device, without logging in. These broadcast streams include ABC TV, ABC NEWS, ABC Kids and ABC ME.
In relation to accessibility, please see pages 14-24 of the draft PIA.
Point 13
Utilising a log-in function for a VOD service is not a radical and unnecessary departure from the behaviour citizens have come to expect of a public service broadcaster. You may be aware that 80% of the European Broadcasting Union members (the world’s foremost alliance of public service media) have a login requirement, including the BBC.

In February the ABC provided a ABC FAQ regarding the iview Login providing:

Introducing Login to Watch means ABC iview can do what the other streaming services and commercial and public broadcasters are already doing and provide the personalised services viewers expect.

Eighty per cent of public service broadcasters in the European Broadcasting Union, for example, require some form of login to access their video on demand service, including the BBC.

In a recent audience survey 95 per cent of respondents flagged a strong interest for ABC iview to add personalisation features that would require a login.

Failing to keep pace with user expectations could lead to a danger that our Australian stories get lost in the mix, or don’t get told at all.

In 2021 ABC iview was Australia’s No 1 broadcaster VOD streaming service with more than 4500 hours of television shows, live performances, and films to enjoy for free – and ad free.

There are currently almost 6 million ABC accounts delivering the benefits of personalised ABC iview services.

Nothing about creating a login for ABC iview changes our editorial independence, integrity or responsibility, including the privacy and data protections audiences expect of the ABC.

The ABC is bound by the Privacy Act and the Australian Privacy Principles. We place a high priority on the protection of personal information, in line with the trust that Australians place in their public broadcaster.

Over the past year the ABC has worked closely with the Office of the Australian Information Commissioner to ensure greater privacy protections than any other streaming service in this country.

We have also consulted broadcasters internationally to develop a best practice approach to the management of personal information.

The ABC has published a Privacy Impact Assessment (PIA).  This is a systematic assessment of a project that identifies the impact that the project might have on the privacy of individuals and sets out recommendations for managing, minimising, or eliminating that impact.

Why do I need an ABC Account?

From March, the ABC will make a user account a requirement to access any video on demand content on ABC iview.

Accessing ABC iview through an account will provide additional features including the ability to;

• • Create watchlists.
  • Pick up a program where you left off, across devices.
  • Be served content recommendations based on your interests.

Viewers will still be able to watch all the ABC’s live broadcast streams on ABC iview web including ABC TV, ABC News, ABC Kids and ABC ME without needing to log in.

When will it become mandatory to log in to an account to access ABC iview?

We will roll out the change to different eligible devices in stages over the next few months commencing, 15 March 2022.

Viewers will still be able to watch all the ABC’s live broadcast streams on ABC iview web including ABC TV, ABC News, ABC Kids and ABC ME without needing to log in.

Why is the ABC making logins mandatory on ABC iview instead of optional?

It is in the public interest to utilise a Login to Watch function as it allows for taxpayer funded content to be located and consumed by the broadest possible audience.

The sheer volume of content on ABC iview means that it can be difficult to locate content that is of interest to audience members. Login to Watch facilitates access to content – it makes it easier to find by means of recommendation.

Further, as a national broadcaster, it is incumbent on the ABC to ensure we use public funds as efficiently as possible. Login to Watch is consistent with this requirement as it provides the reach and scale we require in return for our investment in improved technology and personalisation features.

Viewers are still able to access live ABC broadcast streams, including ABC NEWS, ABC Kids and ABC ME, on ABC iview on the web without creating an account and logging in. All other ABC television and radio services, and the broader suite of ABC apps, are available without creating an account and logging in.

What happens to ABC iview audience members who decline to create an account?

In our most recent audience survey 95 per cent of respondents flagged a strong interest for ABC iview to add personalisation features that would require a login.

There are currently almost 6 million ABC accounts delivering the benefits of personalised ABC iview services.

Viewers are still able to access live ABC broadcast streams, including ABC NEWS, ABC Kids and ABC ME, on ABC iview web without creating an account and logging in.

All other ABC television and radio services, and the broader suite of ABC apps, are available without creating an account and logging in.

Why the delay?

The launch was paused last year to ensure our audiences understood the benefits of an account and the way we manage and protect their personal information. We worked with the Office of the Australian Information Commissioner, to ensure our practices are all in accordance with the Privacy Act and the Australian Privacy Principles, and in line with the trust that Australians place in the ABC.

We have consulted widely, including with the Australian public through research, and public broadcasters internationally, as we develop our best practice approach to the management of personal information.

What data does / will the ABC receive?

To sign up, people will need to provide an email address (unless they opt to sign in using an existing social media account (Apple, Google or Facebook).  As part of the sign-up process, audiences are asked to provide:

1. 1. Their Name (can use a pseudonym or a nickname if they wish)
   2. Their location (Suburb or postcode)
   3. Their YOB (year of birth)
   4. Their Gender (there is a “prefer not to say” option)

ABC account holders may take steps to withhold their personal details, such as using a pseudonym or a dummy email address.

 Who has access to my personal information within the ABC? What does the ABC use the information for?

Visit Privacy at the ABC, where you can find all the latest privacy information and read the ABC Privacy Policy.

The information we collect when you sign up for an ABC Account allows us to provide a personalised experience and understand engagement with our programs and services.

The information includes:

• • First or preferred name: Helps us know how to address you when you are logged in.
  • Year of birth: Helps us recommend content appropriate to your age.
  • Gender: Help us understand how Australians engage with the ABC.
  • Location: For content that may be more locally relevant to you, and to understand how people around Australia engage with the ABC.
  • Email:?To protect your personal information and provide a secure way for you to access and manage your ABC Account.

By logging in, you’re helping us learn how different people enjoy different programs, which in turn helps us offer better content and improved services to all Australians. If you’re concerned about your privacy, you can sign up sign up using a nickname and an email address that does not include your name.

Individuals can access any personal information held by the ABC about them by contacting our privacy officer.

What personal information is shared outside the ABC? Which companies and why? 

If an account has the ‘data sharing’ option on, the ABC may share an encrypted version of an ABC Account Holder’s email address with Google and Facebook, for the purpose of showing that ABC Account Holder promotions for ABC content when they visit Google and Facebook platforms.

This system does not provide Google or Facebook with any information about ABC Account Holder activity on ABC platforms. Rather, Google and Facebook are instructed what ABC promotion to show to a particular group of account holders on their platforms. Google and Facebook only have capacity to serve that promotion if the ABC Account Holder uses the same encrypted email address to log in to their ABC account as they use to log in to their Google or Facebook account.

While this system does not provide Google and Facebook with any information about ABC Account Holder activity on ABC platforms, Google and Facebook are still contractually not permitted to use any information for any other purpose than serving a particular ABC promotion to that account holder.

ABC account holders can opt out of this in the Data and Privacy page of their Account Settings by simply switching a toggle. It is a very easy process. There is also comprehensive, easy to understand information in the Data and Privacy page of their Account Settings.

Why is the data sharing with third parties option defaulted to ‘on’ for user accounts, rather than requiring users to actively opt in?

You will only be required to provide limited data to set up an account: an email, first name (or pseudonym), year of birth, suburb or postcode and gender (there is a ‘prefer not to say’ option for gender). ABC Account holders are free to use an email address that does not include their name and may choose to use a pseudonym instead of their first name.

Once audiences create an ABC account to watch programs on ABC iview, they can opt out of their encrypted email address being shared with Facebook or Google. Email addresses for any child account holders will automatically be opted out.

The ‘data sharing’ option refers to sharing an encrypted version of an ABC Account Holder’s email address with Google and Facebook, for the purpose of showing that ABC Account Holder promotions for ABC content while they visit Google and Facebook platforms.

This system does not provide Google or Facebook with any information about ABC Account Holder activity on ABC platforms. Rather, Google and Facebook are instructed what ABC promotion to show to a particular group of account holders on their platforms. Google and Facebook only have capacity to serve that promotion if the ABC Account Holder uses the same encrypted email address to log in to their ABC account as they use to log in to their Google or Facebook account.

While this system does not provide Google and Facebook with any information about ABC Account Holder activity on ABC platforms, Google and Facebook are still contractually not permitted to use any information for any other purpose than serving a particular promotion to that account holder.

Why is the ABC launching this now while saying it will implement privacy improvements in the future?  Why not wait?

The privacy landscape in Australia is rapidly evolving, from an industry and regulatory perspective, including a current review of the Privacy Act by the Attorney-General’s Department.

Australians can be assured that the ABC will continue to update its systems and measures, to ensure we go above and beyond any requirements in terms of privacy and the use of personal information.

Does the ABC still intend to make logins mandatory for other ABC digital content services (eg: ABC listen app)?

The ABC does not currently intend to introduce log in requirements for other ABC digital content services. Log in is appropriate for ABC iview as it will provide the features audiences expect of a modern Video on Demand (VOD) service, such as picking up where you left off across devices, and creation of a Watchlist. ABC live streams will not require a login to access.

There are some optional features which can only be used with an account on other ABC digital services including the ability to view your playlists across multiple devices on ABC listen.

Learn more about these features by reading the FAQ, What extra features can I access with an ABC Account?

Why is the ABC disclosing device identifiers of unregistered users to Google and Facebook via Tealium, given the user has not given any consent to do so? And what is the device identifier of these unregistered users used for?

The ABC Privacy Policy uses the word ‘may’ in relation to this practice. The ABC is not engaging in this practice and will not do so until further privacy controls are introduced. In this context, these device identifiers would be used in a group to whom a particular ABC promotion could be shown, in a similar way to the process described in the answer above.

 Privacy experts have raised concerns about the latest ABC privacy policy update (see here: https://www.salingerprivacy.com.au/2022/01/06/the-abcs-of-privacy/), including users’ data being shared with companies like Google and Facebook without “active and informed consent”. Would the ABC like to respond to this claim or any other concerns raised in the linked post?

The ABC is bound by the Privacy Act and the Australian Privacy Principles in relation to managing personal information. Under Australian privacy law, in the context of the permissible collection, use and disclosure of personal information, it may be permissible to use notification to create reasonable expectation, rather than seek express consent.

The privacy landscape is a rapidly evolving one from both an industry and regulatory perspective, with the Attorney-General’s Department undergoing a comprehensive review of the Privacy Act currently. Nothing about creating a login for ABC iview changes our editorial independence, integrity or responsibility, including the privacy and data protections people expect of the ABC.

What additional measures have we introduced since ABC Accounts were launched in 2021 re. privacy and use of personal information?

Significant work has been undertaken in providing effective privacy controls, by way of an easy opt out built directly into the introduction of the encrypted email promotions function and the recommendations function.

Updates to the Privacy Policy and the ABC Privacy Collection Statement incorporated clear and comprehensive explanations about any changes to the management of personal information.

How do you think the audiences will react to this?

Almost 6 million ABC accounts already exist. In addition, each week nearly a million people using ABC digital services are logged in through their account. We expect this number to continue to grow as people see the benefits of creating an account and profiles for their family.

Do the features of an account limit the programs I can access or only show me content based on what they think I’m interested in? 

Requiring audiences to have an ABC account will ensure that we continue to be relevant to all Australians, in line with their expectations for on-demand content and personalisation features, such as program watchlists and recommendations. Viewers can follow simple step-by-step guides for setting up an account via our websites or on social media platforms, to ensure they can continue to enjoy ABC iview regardless of their technological skills. The ABC has an accessible and skilled ABC Support Team which provides information and support 7 days a week and 363 days a year.

Of course, all Australians can continue to watch our content via our broadcast channels and other ABC platforms and apps, including the ABC News website and ABC Kids app, if they prefer not to create an ABC account. Viewers will also remain able to access live ABC broadcast streams, including ABC NEWS, ABC Kids and ABC ME on ABC iview on the web without logging in. Separately, viewers with older model televisions that don’t support account technology will not have to create an ABC account. ABC iview will also continue to be accessible without an account via Fetch TV and Foxtel IQ.

Program recommendations based on someone’s viewing history are just that – recommendations only. ABC account holders are free to opt out of receiving personal recommendations, and they will also enjoy general recommendations of content to surprise and delight them. Australians will continue to have access to all our content across multiple genres and topics, ensuring that they are exposed to a diversity of ideas, perspectives and stories.

 Are you going to start charging to watch ABC iview?

No.  The ABC does not charge audiences to watch ABC iview and is not allowed to do so under the ABC Act. This excludes any costs incurred for your internet connection.

Creating an ABC Account is free, and there is no paid advertising on ABC platforms in Australia.

You don’t need to provide any bank or credit card details when signing up for an ABC Account.

How do these changes compare with other broadcasters like SBS?

SBS announced mandatory logins prior to 2019.  SBS requires the following information to login:

• • Emails address;
  • First name;
  • Year of birth; and
  • Gender

SBS offers an opt-out to personalisation services such as content recommendations and interest-based advertising.  The ABC position at launch will be more privacy protective than SBS in the sense that the ABC will offer ‘opt in’ to the disclosure of advertising cookies and SDKs to Facebook and Google.

Has the ABC conducted a Privacy Impact Assessment?

Yes.  The ABC has published a Privacy Impact Assessment (PIA).  

This is a systematic assessment of a project that identifies the impact that the project might have on the privacy of individuals and sets out recommendations for managing, minimising, or eliminating that impact.

Where’s the data stored to enable personalisation and recommendations?

SAP Customer Data Cloud (formerly Gigya), stores first party personal data for ABC Accounts in Australia. That is, key attributes such as plain text email, first name, year of birth and gender.

Tealium, our segmentation engine, takes an encrypted or hashed version of email to drive recommendations. Any personal information provided to Tealium is hosted in Australia.

Tealium passes this hashed email to third parties in Google and Facebook, along with a segment. A segment is simple variable, used to improve the quality of promotions on Facebook and Google.

Both Gigya and Tealium are best of breed systems, which have been certified by our ABC Cybersecurity team.

If I log in to an ABC Account with a Google email address, does Google have access to my ABC viewing data?

The ABC shares data with third parties in accordance with the ABC Privacy Policy. The method of login, or whether you log in with a google email address, does not affect the ABC’s data sharing practices.

How does the ABC protect my child’s privacy online?

The ABC aims to provide a safe digital space for children to enjoy their favourite programs and other content. To make sure children are protected online, we:

• • do not send any data for the purpose of promoting ABC content off ABC platforms, from children’s ABC iview accounts and profiles, and children’s apps;
  • automatically opt-out children’s accounts from Promotions on Digital Platforms;
  • provide easily accessible privacy information to ensure parents and guardians can learn about online privacy, and how it affects their children;
  • provide an easy to understand children’s Privacy Collection Statement written especially for kids;
  • provide dedicated apps for children of all ages, (ABC ME, ABC Kids and ABC Kids listen), featuring parental filters to ensure parents are in control of what their children watch and listen to.

There are real issues which have been identified by Crompton include:

*             the Privacy Policy at https://help.abc.net.au/hc/en-us/articles/360001154976  effectively asks the individual to consent away any of the intended limitations in the Privacy Act such as Collection Limitation or Use Limitation etc. such was where it states that “The purposes for which we collect, use and disclose personal information include: …”. 

*            the Privacy Collection Statement at https://help.abc.net.au/hc/en-us/articles/360001511015 is defective in that it states:

“If you don’t want to see promotional information on those platforms that is informed by your use of ABC digital services, you can opt out via your account settings on those platforms.  You can also visit Your Online Choices and do a blanket opt out for the organisations who signed up to Your Online Choices.”

however the “Your Online Choices”:

•  is solely cookie based which are set separately for each browser  so the individual potentially has to try the opt out in that system for each browser on each device.
• the system loses all choices made by the individual if the individual implements deletes cookies at the end of a session or operates an ad blocker.
• it does not work at all in the vast bulk of businesses allegedly subscribed to the system.
• the link on ABC website goes to the Irish (!) version of Your Online Choices, https://www.youronlinechoices.com/ie/your-ad-choices.
• a ‘consent’ to the ABC privacy policies is not contained in the “privacy” section but rather the Terms of Use in Section 6 and is circular providing:

“You consent to the ABC handling any personal information and other data acquired from your participation in any ABC Online Services in accordance with the ABC Privacy Policy and the ABC Privacy Collection Statement.” 

The fundamental problem is that all of this complaining and arguing is too little too late.  Complaints should have been made when SBS, Channel Nine and Seven not to mention other platforms required log in details.  The argument that ABC is special and distinctive is quite artificial. It is also quite ineffective to write an open letter and a press release at the eleventh hour and somehow expect the ABC to change its direction. 

The bigger problem is that civil society groups concerned about privacy are naifs.  They are utterly inept in properly prosecuting a campaign to effect change.  What work is done is confined to a few press releases and quotes in a paper or two.  No government is going to be bothered by that.  It is better than nothing, but not by much.