Tesco Mobile customers should think twice before viewing ads for a £3 a month discount

Customers have to see “at least one ad, offer or piece of content” on at least 21 days each month to get the discount.

What are people going to be giving up for that £3 a month?
The implication is that customers get the £3 discount for giving up some of their time and attention to see and open or dismiss the adverts. In reality, they are also paying with their data. Tesco Mobile are working with a company called Unlockd to deliver the ads to people’s phones. Tesco Mobile customers have to agree to Unlockd’s privacy policy to get their £3 a month discount.

In addition to collecting customers’ mobile number, email address, age, gender and interests at the signup stage, Unlockd’s privacy policy says they will:

• collect customers’ location data to serve tailored adverts
• create ‘anonymous’ data records of customers’ personal data and use them “for any purpose”
• transfer customers’ personal data to the USA, the UAE, and India and process it there.

The links to Unlockd’s privacy policy are difficult to find. Tesco Mobile’s webpage (which is all most customers are likely to see) doesn’t mention any of these personal data collection issues.

This is an optional scheme and companies should be able to make contracts with their customers. But the bare minimum standard should be that customers are asked for their genuinely informed consent when giving up privacy. This kind of data collection and processing needs to be flagged up much more clearly to customers to meet this standard.

Location data
Somebody’s location data can be very sensitive. It can reveal all kinds of patterns about their life. It’s reasonable to think that lots of people would like to avoid constantly sharing their location with a company that will put adverts on their phone lockscreen every day.

Unlockd’s privacy policy tells customers to turn off location on their phone if they want to “deactivate this feature”. That’s the ‘feature’ of having your location collected to show you ads by the way. But for many people, location-based services like maps are one of the most useful things about having a smartphone. Asking people to give up maps so that they can opt out of their location being collected for advertising purposes isn’t fair or reasonable.

‘Anonymised’ data records
Significant amounts of research have been done illustrating ways in which identifying individuals from anonymised data is both possible and practical. Unlockd saying they can “use and disclose anonymous data for any purpose” [our emphasis] is worrying to say the least.

Personal data transferred and processed abroad
Unlockd’s privacy policy says they may transfer and process personal data to countries “including, but not limited to the United States, the United Arab Emirates and India, where data protection and privacy regulations may not offer the same level of protection as in other parts of the world.”

It is also worrying that people’s data would be transferred to and processed in places where personal data and privacy are not as highly protected as they are in Europe. It is not made clear what the reasons are for data being transferred to and processed in these countries instead of in Europe.

Poverty and privacy
“You can save money by looking at adverts and giving up your personal data” is a message with big implications. Some people may have the means and freedom to choose to give up some privacy and attention for a discount. But for others, seeing adverts on your phone to save £3 on your phone bill might mean your family doesn’t have to skip a meal. Of course it will not only be poorer people who will take Tesco Mobile up on this offer, but the incentive to give up some privacy in this case is surely stronger for poorer people.

We don’t want a society where richer people can afford to retain their privacy and poorer people give up their privacy to make ends meet.

This is similar to what Christopher Soghoian, the ACLU’s principal technologist, calls the “digital security divide”. Richer people are more likely to be able to afford Apple’s iPhone which is encrypted by default. Most people buy cheaper Android phones which are not encrypted by default. In effect this makes it more difficult for thieves to unlock phones belonging to rich people than poorer people.

Customers should be cautious and consider the implications on their privacy before giving up their privacy for a discount. And if this business practice continues, or expands to other sectors, there is a danger that some people will feel they cannot afford not to give up their privacy.