When I started working at Google almost 12 years ago, Australians were still figuring out how to make the most of the internet. Today, few of us could imagine a day without a smartphone in our pocket.

Google provides tools and services that millions of Australians use every day, such as Search, Maps and YouTube. Thousands of Australian businesses are benefiting too, using online platforms like ours to reach customers across Australia and globally.

In its Digital Platforms Inquiry, the Australian Competition and Consumer Commission (ACCC) is considering the impact of these changes, with a particular focus on news and journalism.

The ACCC notes the Internet has helped consumers to access a broader range of news publications, as lower production and distribution costs have sparked competition from new entrants, both locally and around the world. As this occurred, traditionally profitable sections of newspapers such as real estate and classifieds have faced new competition for advertising dollars, not just from platforms like Google, Facebook and Amazon, but also from Australian digital success stories like SEEK, Domain and REA.

In short, as Australians have increasingly gone online, so too have advertisers. The ACCC’s Preliminary Report proposes a number of regulatory ideas in response to this transition. We have engaged with the ACCC throughout this process and this week submitted our response to the Preliminary Report.

Underpinning our submission is a belief that as technology evolves, legal frameworks must also evolve with clear, evidence-based solutions to address specific problems. It’s sometimes claimed that the internet is unregulated but that's simply not the case. Considered, carefully calibrated regulation has contributed to the web’s success as a platform for expression and access to information.

We respect the range of existing laws and regulations that apply to the internet, such as competition and consumer laws and advertising regulations. This inquiry provides a timely opportunity to review and consider existing frameworks in light of rapid change.

Working with news publishers to enable quality journalism 
When Australians search for news on Google, we want to surface high quality, relevant and useful results. In 2018, we referred more than 2 billion clicks to Australian news websites. These clicks amount to free traffic that helps publishers generate ad revenue and provides the opportunity to turn casual readers into loyal subscribers. We also provide ad technology to large and small publishers to help them monetise content through advertising. In 2018, we paid US$14.2 billion to partners globally - more than 70% of the revenues earned from displaying ads served by Google on partners’ properties.

Google News has no ads, nor does the news results tab on the search page. Unlike social media sites, which operate in largely closed environments and benefit from users spending more time on the site, the success of Google Search relies on linking users with relevant results. This is an important distinction, highlighting the need to differentiate between digital platforms.

While Google supports news and journalism, some of the Preliminary Report’s recommendations - such as an algorithm regulator - risk poor outcomes. We already provide extensive guidance on search ranking, including our 164 page Search quality rater guidelines, and the How Search Works guide. And of course, Google Search results are open for all to see. We believe this approach balances the need for transparency against the risk of manipulation by bad actors and do not believe that an algorithm regulator would lead to higher quality search results or promote journalism.

Providing useful products and services for consumers and advertisers
Australians search for a wide range of queries every day and expect to get the most relevant and useful results, as quickly as possible. While Search is very popular, we have a lot of competition. From a consumer perspective, Google competes for user queries with other search engines, and specialised search services like Amazon, e-commerce sites and travel aggregators.

From an advertising perspective, search advertising is just one of many channels advertisers invest in and we compete directly for advertising dollars with other digital channels, as well as television, print, radio and outdoor advertising. The popularity of digital is, in part, due to the unprecedented ability it provides for advertisers to measure the impact of their ad spend and other media channels are fast catching up. This is not examined in the Preliminary Report and we believe there should be further consideration of the competition Google faces for user queries on search and the competition for advertising investment, both among digital providers (of which search advertising is only one part) and other forms of advertising.

Protecting Australians’ privacy 
Australians trust us to protect their privacy and data, and we take that responsibility seriously. Through Google’s MyAccount we provide easy to use tools that give people transparency, choice and control over their data. In 2017, Australians visited MyAccount more than 22 million times, reviewing and adjusting their privacy settings to manage what information is collected and how that data is used.

The Preliminary Report proposes a range of measures to enhance privacy and consumers’ awareness of data collection and use. We believe these changes should apply to all organisations currently subject to the Privacy Act, not just digital platforms or organisations that meet a particular threshold. 

The ACCC’s preliminary report provides a timely opportunity to examine Australia’s changing media and advertising landscape. As we continue to engage in this process, we do so with the goal of balancing the benefits of new technologies, minimising societal costs, and respecting fundamental rights for all Australians.

Posted by Mel Silva, Managing Director, Google Australia