“We are offended by the ludicrous and utterly ill-informed assertion in your letter dated January 24, 2013, that we would in any way haphazardly or recklessly introduce a program that manipulates children, or wantonly puts their safety at risk.” – Bob Iger to Rep. Edward Markey
In a sharply worded letter to Congressman Edward Markey, Bob Iger refuted claims by the congressman who said, “I am deeply concerned that Disney’s proposal could potentially have a harmful impact on our children.” The basis of his concern came from an article in the New York Times about the MyMagic+ system that was recently unveiled by the Walt Disney company.
Here is the letter from Bob Iger:
January 28, 2013
The Honorable Edward Markey
2108 Rayburn House Office Building Washington, DC 20515
For 90 years, Disney has been synonymous with high-quality entertainment for families and children of all ages. We use creativity, innovation and technology to create memorable moments and experiences for our hundreds of millions of customers and guests. And, as you well know, Disney’s record and commitment to children’s safety and security and the protection of their privacy is exemplary. People around the world trust Disney and its products. That trust is the cornerstone of our company, and we take it very seriously.
We are offended by the ludicrous and utterly ill-informed assertion in your letter dated January 24, 2013, that we would in any way haphazardly or recklessly introduce a program that manipulates children, or wantonly puts their safety at risk.
It is truly unfortunate and extremely disappointing that you chose to publicly attack us before taking the time to review our policies and/or contact us for information, which would have obviated the need for your letter. Had you or your staff made the slightest effort, you would have found most of the answers to your questions already existed and were publicly available online at http://corporate.disney.go.com/corporate/pp.html and https://disneyworld.disney.go.com/faq/my-disney-experience/privacy-policy/.
In the enclosed attachment, we address the questions in your letter about our new, yet-to-be launched program, MyMagic+. However, to ensure that you fully understand our practices as they pertain to children, and our commitment to our guests’ privacy, let me be clear and reiterate the basic facts.
MyMagic+ is a completely optional program that was designed with privacy controls from the outset. Disney does not use personal information to market to children under age 13, does not personalize or target advertisements to an individual child, and never shares children’s personal information with any third party for their marketing purposes. Additionally, parents have full control over their child’s participation in MyMagic+. We have transparent privacy practices, guests can control and limit the amount of information they provide to us — and how their information is used.
Further details are attached
Robert A Iger
This letter was in response to the following letter from Rep. Edward Makey:
January 24, 2013
Mr. Robert A. Iger
Chairman and Chief Executive Ofñcer The Walt Disney Company
500 S. Buena Vista Street
Burbank, CA 91505
Dear Mr. Iger:
According to a January 7, 2013, New York Times article (“At Disney Parks, a Bracelet Meant to Build Loyalty (and Sales)”), Disney plans to introduce a new vacation management system called MyMagic+ that will substantially change how visitors experience Disney parks and resorts. Under the proposal, guests will have the option to wear radio frequency identification chips, or MagicBands, that will serve as a credit card, room key, and park ticket, among other functions. Although this change has the potential to make it easier for visitors to enjoy Disney amusement parks, the plan also raises a number of important questions about how the personal privacy of Disney’s 30 million guests each year will be protected, particularly when it comes to kids and teenagers.
This Times article reports that this spring, Disney plans to implement MyMagic+, an initiative to “make visiting Disney parks less daunting and more amenable to modern consumer behavior.” As part of this plan, Disney guests will be able to use MagicBand bracelets encoded with credit card information that will allow visitors to enter the park and purchase items with ease.
Widespread use of MagicBand bracelets by park guests could dramatically increase the personal data Disney can collect about its guests. The Times article explains that MyMagic+ “will allow Disney for the first time to track guest behavior in minute detail.” This information could include what attractions guests ride and when, what food and souvenirs they buy, and even what characters’ hands they shake. The article also explains that, “MagicBands can also be encoded with personal details, allowing for more personalized interaction with Disney employees.” These details could include park employees knowing your name or even if you are celebrating your birthday.
Collecting information about how guests use Disney amusement parks could improve the company’s ability to target advertisements at its guests, including children. The Times article points out: “If you fully use MyMagic+, databases will be watching, allowing Disney to reñne its offerings and customize its marketing messages.” Although kids should have the chance to meet Mickey Mouse, this memorable meeting should not be manipulated through surreptitious use of a child’s personal information.
As a CoChairman of the Congressional Bipartisan Privacy Caucus, I am deeply concerned that Disney’s proposal could potentially have a harmful impact on our children. I request written responses to the following questions:
1. Will Disney guests be required to use MagicBand‘? Please explain.
a. For guests that use MagicBand, will those guests be given an option to decide
whether to share personal information with your company? If no, why not?
i. If yes, will consumers be given a choice to to information sharing or from information sharing? Please explain how and when guests will be given this choice.
ii. If yes, will you give consumers a choice about what types of information
guests will share with your company (the Times article describes MagicBand users as selecting certain “settings”)? If yes, please list those types of information (e.g., geolocation, items purchased, attractions visited, etc.).
iii. Are there any types of information that consumers must share with your
company if they use MagicBand?
b. If a guest chooses not to use MagicBand, what disadvantages, if any, will that
guest experience while visiting a Disney park (i.e., longer waits for attractions, etc.)‘?
2. What information do you plan to collect from Disney guests who wear MagicBands, including but not limited to geolocation, items purchased, and attractions visited?
a. Does the information you collect depend on the age of the guest? If no, why not?
If yes, please explain what policies will apply to specific age groups.
3. Will Disney analyze this data using predictive analytics and other measures to help create
profiles of guests? If yes, what other data variables of guests may be included if profiles are created? If yes, will Disney create profiles for all guests, including kids and teens? Please explain.
4. Does your company plan to use the information collected from MagicBands to target
advertisements and marketing at guests? If yes, please explain the ways in which you plan to target advertisements and marketing, including but not limited to geolocation targeting on mobile devices.
a. If yes, do you plan to target advertisements at kids 12 and under? If yes, please
explain the ways in which you plan to target advertisements at children.
b. If yes, do you plan to target advertisements at teens? If yes, please explain the
ways in which you plan to target advertisements at teens.
c. If yes, do you plan to target advertisements or marketing at guests only when they are inside of Disney parks? If no, please list the other places where your company plans to target advertisements or marketing at guests. If no, what kinds of products may be promoted if such marketing occurs?
5. Does your company plan to market, sell, or otherwise disclose personal information or
proñles about its guests to other companies? If yes, please explain.
6. Does your company plan to share the information it collects about its visitors with Disney
affiliates, such as the Disney Channel or Disney Farnily.com? If yes, for what purposes do you plan to share that information (e. g., for targeted advertising purposes or marketing)? If yes, please list the affiliates with which you plan to share this information.
7. How long does your company plan to use or store information collected about its guests
a. Does your company have procedures in place to minimize the information it
stores about guests?
b. What procedures does your company employ to ensure deletion of information?
c. Are consumers given reasonable access to review and delete this data?
Thank you for your attention to this important matter. Please provide a response no later than February 14, 2013. If you have any questions, please have a member of your staff contact Joseph Wender at 202-225-2836.
Edward J. Markey
CoChairman Congressional Bi-Partisan Privacy Caucus