By Sam Biddle

From The Intercept | Original Article

Federal contract materials outline plans to geofence 67 different public high schools throughout the state and to target phones with recruitment ads.

The Georgia Army National Guard plans to combine two deeply controversial practices — military recruiting at schools and location-based phone surveillance — to persuade teens to enlist, according to contract documents reviewed by The Intercept.

The federal contract materials outline plans by the Georgia Army National Guard to geofence 67 different public high schools throughout the state, targeting phones found within a one-mile boundary of their campuses with recruiting advertisements “with the intent of generating qualified leads of potential applicants for enlistment while also raising awareness of the Georgia Army National Guard.” Geofencing refers generally to the practice of drawing a virtual border around a real-world area and is often used in the context of surveillance-based advertising as well as more traditional law enforcement and intelligence surveillance. The Department of Defense expects interested vendors to deliver a minimum of 3.5 million ad views and 250,000 clicks, according to the contract paperwork.

While the deadline for vendors attempting to win the contract was the end of this past February, no public winner has been announced.

The ad campaign will make use of a variety of surveillance advertising techniques, including capturing the unique device IDs of student phones, tracking pixels, and IP address tracking. It will also plaster recruiting solicitations across Instagram, Snapchat, streaming television, and music apps. The documents note that “TikTok is banned for official DOD use (to include advertising),” owing to allegations that the app is a manipulative, dangerous conduit for hypothetical Chinese government propaganda.

The Georgia Army National Guard did not respond to a request for comment.

While the planned campaign appears primarily aimed at persuading high school students to sign up, the Guard is also asking potential vendors to also target “parents or centers of influence (i.e. coaches, school counselors, etc.)” with recruiting ads. The campaign plans not only call for broadcasting recruitment ads to kids at school, but also for pro-Guard ads to follow these students around as they continue using the internet and other apps, a practice known as retargeting. And while the digital campaign may begin within the confines of the classroom, it won’t remain there: One procurement document states the Guard is interested in “retargeting to high school students after school hours when they are at home,” as well as “after school hours. … This will allow us to capture potential leads while at after-school events.”

“Location based tracking is not legitimate. It’s largely based on the collecting of people’s location data that they’re not aware of and haven’t given meaningful permission for.”

Although it’s possible that children caught in the geofence might have encountered a recruiter anyway — the 2001 No Child Left Behind Act mandated providing military recruiters with students’ contact information — critics of the plan say the use of geolocational data is an inherently invasive act. “Location based tracking is not legitimate,” said Jay Stanley, a senior policy analyst with the American Civil Liberties Union. “It’s largely based on the collecting of people’s location data that they’re not aware of and haven’t given meaningful permission for.” The complex technology underpinning a practice like geofencing can obscure what it’s really accomplishing, argues Benjamin Lynde, an attorney with the ACLU of Georgia. “I think we have to start putting electronic surveillance in the context of what we would accept if it weren’t electronic,” Lynde told The Intercept. “If there were military recruiters taking pictures of students and trying to identify them that way, parents wouldn’t think that conduct is acceptable.” Lynde added that the ACLU of Georgia did not believe there were any state laws constraining geofence surveillance.

The sale and use of location data is largely uncontrolled in the United States, and the legal and regulatory vacuum has created an unscrupulous cottage industry of brokers and analytics firms that turn our phones’ GPS pings into a commodity. The practice has allowed for a variety of applications, including geofence warrants that compel companies like Google to give police a list of every device within a targeted area at a given time. Last year, The Intercept reported on a closed-door technology demo in which a private surveillance firm geofenced the National Security Agency and CIA headquarters to track who came and went.

Although critics of geofencing point to the practice’s invasiveness, they also argue that the inherent messiness of Wi-Fi and Bluetooth signals means that the results are prone to inaccuracy. “This creates the possibility of both false positives and false negatives,” the Electronic Frontier Foundation wrote earlier this year in a Supreme Court amicus brief opposing geofence warrants served to Google. “People could be implicated for a crime when they were nowhere near the scene, or the actual perpetrator might not be included at all in the data Google provides to police.”

It’s doubtful that potential vendors for the Georgia Guard have data accurate enough to avoid targeting kids under 17, according to Zach Edwards, a cybersecurity researcher who closely tracks the surveillance advertising sector. “It would also sweep up plenty of families with young kids who gave them phones before they turned 16 and who were using networks that had location-targetable ads,” he explained in a message to The Intercept. “Very, very few advertising networks track the age of kids under 18. It’s one giant bucket.”

In-school recruiting been hotly debated for decades, both defended as a necessary means of maintaining an all-volunteer military and condemned as a coercive practice that exploits the immaturity of young students. While the state’s plan specifies targeting only high school juniors and seniors ages 17 and above, demographic ad targeting is known to be error prone, and experts told The Intercept it’s possible the recruiting messages could reach the phones of younger children. “Generally, commercial databases aren’t known for their high levels of accuracy,” explained the ACLU’s Stanley. “If you have some incorrect ages in there, it’s really not a big deal [to the broker].” The accuracy of demographic targeting aside, there’s also a problem of geographic reality: “There are middle schools within a mile of those high schools,” according to Lynde of the ACLU of Georgia. “There’s no way there can be a specific delineation of who they’re targeting in that geofence.”

Indeed, dozens of the schools pegged for geotargeting have middle schools, elementary schools, parks, churches, and other sites where children may congregate within a mile radius, according to Google Maps. A geofence containing Hillgrove High School in Powder Springs, Georgia, would also snare phone-toting students at Still Elementary School and Lovinggood Middle School, the latter a mere thousand feet away. A mile-radius around Collins Hill High School in Suwanee, Georgia, would also include the Walnut Grove Elementary School, along with the nearby Oak Meadow Montessori School, a community swim club, a public park, and an aquatic center. Lynde, who himself enlisted with the Georgia National Guard in 2005, added that he’s concerned beaming recruiting ads directly to kids’ phones “could be a means to bypass parental involvement in the recruiting process,” allowing the state to circumvent the scrutiny adults might bring to traditional military recruiting methods like brochures and phone calls to a child’s house. “Parents should be involved from the onset.”