Joint letter calling the FTC to protect bystanders from dangerous and harmful surveillance

Lina Khan, Chair Federal Trade Commission 
Rebecca Kelly Slaughter Commissioner 
Alvaro Bedoya, Commissioner

Re: FTC protecting against collective harms posed by Amazon surveillance network

Dear Chair Khan and Commissioners,

The undersigned organizations urge the Federal Trade Commission (FTC) to use its authority to investigate the collective harms posed by the widespread, unregulated Amazon Ring surveillance and data collection network. 
Dear Chair Khan and Commissioners,

The undersigned organizations urge the Federal Trade Commission (FTC) to use its authority to investigate the collective harms posed by the widespread, unregulated Amazon Ring surveillance and data collection network. 

Amazon’s Ring network consists of internet-connected consumer products, including doorbell cameras, floodlight cameras, mailbox sensors, and car dash cams. Reports estimate over 10 million U.S. households own a Ring device, giving Amazon the ability to surveil millions of unsuspecting people—primarily bystanders and delivery drivers captured on camera. 

Ring owners unwittingly collect troves of lucrative data sets for Amazon, allowing them to own limitless amounts of personal data about everyone surveilled—including where they go and what they do. Additionally, in capturing peoples’ likeness, Amazon gains access to biometric data that is biologically unique to each person. Amazon may use this data for its own commercial purposes, such as developing applications for policing or intrusive targeted advertisements, and could even share this data with third parties. The tech giant’s unrestricted dominion over this highly sensitive information exposes the public at large to continuous privacy violations, data abuse, and unwarranted criminalization.

This is even more concerning as Amazon has sought to establish itself as a major player in the development of artificial intelligence, which requires vast troves of data and can be used to manipulate people’s consumer habits and beyond.

There is little people can reasonably do to avoid these harms. Amazon’s network of Ring devices is ubiquitous and uses methods of data collection that defy traditional notions of privacy. Individuals are subjected to being filmed while going about their daily lives. A doctor’s visit, dropping kids off at school, walking the dog, delivering food or a package, and other seemingly mundane activities are collected by Amazon. Once Amazon has an individual’s data, including their biometric information, that individual is permanently vulnerable to data abuse and exploitation.

All of this takes place without knowledge or consent. While Amazon’s interface requires individual Ring owners to agree with terms of service, the bystanders recorded by Ring surveillance devices enter no such agreement. An individual cannot give consent on the behalf of the collective. Moreover, it is questionable whether any individual can meaningfully consent to the unknowable future of far-reaching harms implicit in consenting to Amazon surveillance. 

This may be particularly true in communities of color, which are disproportionately policed and often targeted with predatory advertising and scams.

While the FTC does not have jurisdiction over police use of Ring, it should look into the harm caused by consumer products used for civilian policing. Ring network’s accompanying social media app, Neighbors, provides a seamless way for those self-policing their neighborhoods. Despite the way it’s marketed, this is not your ordinary neighborhood watch app. Through Neighbors, Amazon recruits users using fear-inducing tactics, stoking paranoia and racial prejudice to engage users on the platform. Riddled with racist stereotypes and profiling, Neighbors gamifies the surveillance of neighbors, bystanders, and visitors—further subjecting Black and brown people to criminalization, threat of police violence, and neighborhood vigilantes. 

Civil rights organizations have warned that incidents such as the murder of Trayvon Martin will continue to escalate with the rise of consumer surveillance networks, like Amazon Ring. And after the Supreme Court’s decision in Dobbs v. Jackson, reproductive rights and privacy advocacy organizations have been sounding the alarm about people using Ring surveillance devices to surveil abortion patients and providers and then sharing that footage on Neighbors.

The Commission has a clear mandate to protect against these harms. The FTC has made it clear that substantial harm can be demonstrated by incidental “harm to a large number of people.” In doing so, the agency established the importance of evaluating the impact on the collective, not just individual consumers. It’s within the FTC’s purview to target Amazon’s data collection practices. Every second an individual Ring camera records members of the public constitutes a harm—and millions of seemingly small but potentially life-altering instances of harm are happening in communities across the country.

We’re encouraged by the FTC’s actions earlier this year bringing actions to hold Amazon accountable for violations of customers’ privacy, lax security practices, and abuse of monopoly power. But it can’t stop there: the prior investigation simply did not account for the collective harm caused by Ring. As such, consumers and the wider public are vulnerable to continuous misuse of their data, discrimination, and other harms associated with data breaches, data brokers, and deputized civilian vigilantes.

While the Commission has already initiated a rulemaking that could address some of these harms, immediate action on the harms of the Ring surveillance network is required. Amazon’s surveillance machine grows with each purchase of a Ring device—putting more and more people at risk. It’s incumbent upon the FTC to investigate and use its authority to mitigate the dangers posed to consumers and the public at large by Amazon Ring. In doing so, the Commission takes the steps necessary to stop Amazon and other surveillance-driven, data-collecting corporations from further misusing and exploiting our personal lives.

Sincerely,

Fight for the Future, Access Now, Accountable Tech, Aspiration, Athena Coalition, Center on Race and Digital Justice, Community Justice Exchange, Constitutional Alliance, For the Many, Free Press, Institute for Local Self-Reliance, Just Futures Law, Kairos Action, Main Street Alliance, May First Movement Technology, MediaJustice, Open MIC, Progressive Technology Project, Public Citizen, RootsAction.org, Surveillance Resistance Lab, Surveillance Technology Oversight Project, United Church of Christ Media Justice Ministry, United We Dream, WA People’s Privacy and Woodhull Freedom Foundation