10/5/2012. Intro to Data Collection & The Online Privacy Landscape THE WEB RUNS ON DATA. Blane Sims BrightTag. The Web Runs on Data

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1 Intro to Data Collection & The Online Privacy Landscape Blane Sims BrightTag THE WEB RUNS ON DATA The Web Runs on Data Big Data organizes the web and drives technical innovation Every 2 days, we create as much information as we did from the dawn of civilization up until 2003 > 1.8 zettabytes last year Behavioral data is key to making all of this information accessible and relevant to humans New York Times Sept. 8,

2 Discover New Products 4 What You Need When You Need It 5 The Most Pertinent News 6 2

3 Free Content for Everyone 7 Communicating With A Crowd Cultivating Customer Relationships 3

4 HOW DATA COLLECTION WORKS Third-Party Tags What is a third-party tag? Tags are pieces of code that execute in web browser/app software Tags instruct browsers to collect data, set cookies and insert third-party content into a website Also known as pixels, beacons Why are tags used? Data collection for measurement and targeted marketing Audience extension between multiple websites Inserting ads, social media widgets, video players, personalized content and more onto a website What do tags look like? Tags are part of the HTML/JavaScript code delivered to the browser when a web page loads 11 How Data Collection Works 1. Web browser requests web page from website s servers 2. Website servers send page content and third-party tag code to browser Web Server 3. Browser executes tag code and collects data <script type="text/javascript"> var Src = window.location.protocol + "//pixel.example.com?"+ "_com=28&_fid=101&_cid=1001&_cmagic=abcdef&_format=5";... </script> 4. Tag code instructs browser to send data to data collection server 5. Data Collection web server sends cookie data in its response, browser stores cookie based on user preferences Third-Party Data Collection Server 12 4

5 What Data Gets Collected? User Context: Implicit information is passed with every request to a web server IP Address of device Type of web browser How you were referred to the site (Google Search, Ad click-through, etc.) User Profile: Anonymous data stored in cookies Profile ID Targeting criteria, including segment identifiers Previously stored data points User Behavior: Data points that allow for measurement & targeting Products viewed and purchased Content and ads viewed Personal interests on social media sites (what you like ) On-Page Actions (links clicked, time on page, scrolling, etc.) Note: Any content present or any actions taken in the browser can potentially be captured as a data point 13 The Type of Data Collected by Tags and the list goes on 14 Tags & Cookies Tags are not cookies & cookies are not tags Tags do cause cookies to be sent to the browser Cookies are not the only way to persistently identify a user 15 5

6 Though not widely used, alternatives to cookies do exist Flash Cookies (Local Stored Objects) HTML 5 Storage HTTP ETags (Browser Cache) Device Identification 16 Other Persistent ID Techniques Fingerprinting Unique device identifiers (UDID, MAC, etc.) Other uses of browser capabilities: History sniffing Window.name caching HTML 5 Canvas caching COMPLEXITY MAKES CONTROL DIFFICULT Typical Uses of Behavioral Data Key activities: Analytics Personalization Search Social Media Affiliates Behavioral Ads 6

7 Just How Many Tags are There? Source: Luma Partners (Feb. 2012) Many-to-Many Data Relationships Publishers Retargeters Affiliates Analytics DMPs DSPs Example: Real-Time Bidding Marketer Site (Behavioral Data) Publisher Site (Targeted User) Targeted Ad Buy an Ad Sell an Ad Targeted Ad Server Demand-Side Platform Ad Exchange Supply-Side Platform Direct-Buy Ad Network 7

8 PRIVACY AND DATA ARE INTERTWINED Multiple Tags Put Privacy at Risk Inverse correlation between the amount of 3rd-party code on a site and the site s performance and privacy controls Tags Performance Privacy 23 Example: We Ordered Pizza Online 24 8

9 & This Showed Up in our Browser 120 tracking tags from 30 marketing partners 25 Privacy Governance Challenges Who is responsible for providing optout? How can choices be made clear to consumers? What does opting out do? How are different regulatory frameworks supported? 26 Live Demo Privacy options at the point of data collection 27 9

10 Key Takeaways Data drives the digital economy Tags collect and link data Piggybacking creates privacy challenges Privacy must be managed at the source of data collection THE CURRENT LANDSCAPE Questions? 10

11 OBA ABCs Fran Maier TRUSTe OBA ABCs Definitions Self-Regulatory Overview Consumer Response Advertiser and Publisher Issues Largest DAA OBA compliance provider, with over 100 billion impressions served. Europe Mobile Emerging Issues: Data Leakage What Is Behavioral Advertising? What OBA is What OBA is not Retargeting users across unaffiliated websites Tracking users with cookies across unaffiliated websites Demographic targeting across unaffiliated websites Run of site advertising Contextual advertising First-party demographic targeting on a single site Analytics or Ad Reporting 11

12 Targeted Advertising and Emerging Regulations Targeting can improve ad performance by 2x NAI Study showed a 2X+ increase in conversion rates for behaviorally targeted ads vs. run of network. But, Ad Targeting has Consumers and Regulators Concerned 54% of consumers do not like OBA 1 and these concerns have led to proposed regulations and are limiting spending on OBA by up to 98% 2 This lead The Digital Advertising Alliance (DAA) to create an OBA self-regulatory program The DAA program calls for companies to provide consumers with notice and choice around behavioral advertising. 1: Source: TRUSTe/Harris Survey, May, : Source: Ponemon Institute Research Report, April 2010 July, 2009: OBA Privacy Concerns Lead to Formation of DAA Self-Regulatory Principles for Online Behavioral Advertising Seven Principles: Education Transparency Consumer control Data security Material change Sensitive data Accountability Two Key Requirements: Notice Choice The DAA Oversees U.S. Self-Reg The Digital Advertising Alliance (DAA) Self-Regulatory Program For Behavioral Advertising Advertising Option Icon 12

13 The DAA Self- Regulatory Program Self-Regulatory Program for OBA Offers consumers a robust and credible program of notice and choice for online behavioral advertising DAA Released OBA principles DAA launches icon and self-regulatory program DAA released multi-site data principles Will DAA release mobile OBA principles? Advertiser Compliance 1 Insert AdChoices icon on ad display. 2 When clicked, the icon launches an ad privacy notice interstitial. 3 Users can then click on to opt-out choice mechanism or company privacy policy. Publisher Compliance 1 Insert AdChoices icon on page footer or adjacent to behavioral ads. 2 When clicked, the icon launches a pop-up privacy notice and opt-out choices. 13

14 The Enforcement Process The Council of Better Business Bureaus Direct Marketing Association BBB Consumer Complaint Submission Form Substantial Program Growth in 1.5 Years Today 400+ companies comply 900 billion compliant impressions per month All top-15 global advertisers participate, including: American Express, AT&T, Disney, General Motors, Kraft Foods, Microsoft and Walmart It s great to see that companies are stepping up to our challenge to protect privacy so consumers have greater choice and control over how they are tracked online. More needs to be done, but the work they have done so far is very encouraging. FTC Endorsement FTC Chairman Jon Leibowitz (2/23/2012) 14

15 Consumer Privacy Bill of Rights Seven principles: Individual control: give them choice Transparency: give them clear and conspicuous notice Respect for context: don't use their data in unexpected ways Security: protect their data from abuse and theft Access and accuracy: let them see and correct their data Focused collection: don't take more of their data than you need Accountability: adhere to these principles in a meaningful way DAA Support for DNT Today the DAA announced that it will immediately begin work to add browserbased header signals to the set of tools by which consumers can express their preferences under the DAA Principles. The DAA expects that such functionality will be implemented within nine months. -DAA, 2/22/12 Consumers Feel More Positive Toward Compliant Advertisers Source: 2011 Consumer Online Survey: Harris Interactive on behalf of TRUSTe 15

16 Consumer Icon Awareness Is Low Source: 2011 Consumer Online Survey: Harris Interactive on behalf of TRUSTe Opt-out Rates Fall Well Below 1% Between 1 and 5 people opt-out for every 10,000,0000 ads Source: 2011 TRUSTe Analysis Based on 10M compliant ad impressions DAA Public Awareness Campaign 16

17 What Are Your Compliance Options? Do Nothing Expose your company to possible lawsuits and regulatory intervention. Risk losing business to compliant competitors. Build Your Own Solution Invest significant capital and resources to build custom compliance technology. Run the risk of not meeting DAA requirements. Buy Only on DAA Compliant Ad Inventory Vendor(s) in control of notice/message Vendor(s) may place icon incorrectly Little or no reporting Partner with a DAA-approved solution provider Cost effective Simple, scalable and flexible Full customer support & guidance Benefit from other customer learning s Self-Compliance Vs. 3 rd Party Providers D.I.Y. Compliance Self-certification to DAA principles Compliance Providers DAA pre-approved Must build and integrate technology from scratch Pre-integrated, scalable technology platforms Self-reporting and monitoring Automated reporting and monitoring Considerations For Selecting A 3rd Party Provider Brand/Reputation Experience Scale Integration with Platforms/Ad Networks Integrated Privacy Program Additional Capabilities Customization Monitoring and Reporting Cost 17

18 Advertiser Considerations Are my ad impressions compliant? Do privacy notices reflect my brand and data activities? Can consumers opt-out of my targeted ads? What 3 rd parties are involved in serving my ad, and do they engage in compliant tracking activities? Publisher Considerations Do I serve behavioral ads on my page? < tracking pixel > < flash cookie > < http cookie > <social plug-in > Privacy Policy Ad What 3 rd party trackers are on my site? Are their and my tracking activities accurately described in my privacy policy? Can consumers opt-out of these tracking activities? Are these trackers compliant? How To Get Started Get DAA Compliant Identify a point person for OBA self-regulation Educate your organization on DAA guidelines Set up an OBA compliance trial quickly and easily License the DAA Icon Beyond DAA Compliance Monitor evolving regulatory news Monitor / Address browser-based Do Not Track developments Monitor emerging European OBA news Data Leakage do you know your whole story? Consider your Mobile App Activities 18

19 What About Europe? 2009 EU Cookie Directive Requirements Inform consumers their data is being processed Get consumer consent prior to storing or accessing information on the consumer s computer or other device. Give consumers access to their data to correct it or delete it Directive 2009/136/EC Use consumer data only for disclosed purposes Data cannot be transferred outside of EU unless these data protection standards are met. The EU Privacy Directive Process 1 The European Commission passes a directive. 2 Each country must enact the directive in their law. 3 That law is enforced by the country s data protection authority. 19

20 Only 8 EU Member Countries Have Complied To Date Have enacted a law Denmark Estonia Finland UK France Malta Ireland Sweden Covered by existing law Germany That still leaves 18 other EU member countries How Will This Impact You? analytics, targeted advertising, site personalization, shopping cart management, visitor preferences, web beacons If: You use cookies or other tracking technology to store or access information from EU citizens on their computers or devices How Will This Impact You? analytics, targeted advertising, site personalization, shopping cart management, PERMISSION PLEASE! visitor preferences, web beacons YES OR NO Then: You must comply and get permission before they are placed or used 20

21 What Could Opt-In Look Like? Data Leakage zombie 8/ Clearspring & Quantcast circumventing cookie deletion 7/ WSJ exposing prevalence of tracking 3/2011 CMU study found NAI & DAA members not fully compliant with their own requirements 7/2011 Stanford study found Epic Marketplace history stealing on Flixster 7/ KISS metrics evading browser choices on Hulu & Spotify 8/2011 Microsoft called for using super cookies w/o disclosures Lack of Awareness Leads to Bad Surprises $2.4M class action settlement Spawned scramble by top-50 Web sites Cast doubt on effectiveness of standards Epic lost pubs and dollars defending itself KISS metrics lost major clients including Hulu Shook advertiser confidence; MSFT retooled sites 9/2011 Facebook called out for practice of tracking users after they have logged out Multiple lawsuits claiming Facebook violating US ECPA (wiretap law) 10/2011 Pandora exposes users music listening history Facing privacy lawsuit from users in Michigan; bad press 21

22 Platforms Face Data Privacy Awareness Challenges Collection awareness - Who is collecting data? - How data is collected? - How is it stored? Use awareness - What sort of data is used? - Use cases? In what combinations? - How is data shared? Code awareness - What does the code really do? - nth party code interactions - Sync ing disclosures & compliance with actual code function Data Transparency - Scope Data Inputs Data Uses Data Outputs Icon Serving Is Just The Tip Of The Iceberg FTC EU DAA APEC Platform Code: JavaScript / Cookies / DNT / Meta-data / Data Sync ing / E-tags / LSOs / etc. 22

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