Building the Digital Out-Of-Home Privacy Infrastructure

Size: px
Start display at page:

Download "Building the Digital Out-Of-Home Privacy Infrastructure"

Transcription

1 Building the Digital Out-Of-Hme Privacy Infrastructure March 1, 2010 Intrductin Digital Out-Of-Hme (DOOH), als knwn as digital signage r smart signs, is a cmmunicatins medium characterized by a dynamic display presenting messages in a public envirnment.1 One f the mst cmmn examples f DOOH media is a flat screen televisin displaying a lp f advertisements in retail stres. Other DOOH units take the frm f kisks, prjectrs r digital billbards. The units appear in a brad range f settings, including in shpping malls, hspitals and dctrsʼ ffices, public transprtatin, gas statins, restaurants, gvernment facilities and public schls. The messaging cntent is ften cntrlled via cmputer, enabling ne master lcatin t cntrl many netwrked units. The medium is a prminent part f the shift in cmmunicatins and advertising away frm traditinal ffline media.2 DOOH has rapidly grwn int a multibillindllar industry ver the past decade. Despite the ecnmic dwnturn, industry frecasts predict grwth at duble-digit rates fr the next 3-5 years.3 There were an estimated 630,000 displays in the United States in 2007, thugh there are many mre wrldwide, particularly in China.4 1 Digital Signage Resurce, Digital Signage Terms Glssary, (last visited Jan. 3, 2010). 2 VSS Frecast Shws Majr Shifts in Cmmunicatins Industry Grwth Patterns, Digital Signage Exp, Sep. 14, 2009, ArticleID/1854/reftab/67/t/VSS-Frecast-Shws-Majr-Shifts-in-Cmmunicatins-IndustryGrwth-Patterns/Default.aspx. 3 Frecasts Shw Digital Out-f-Hme Still n Track fr Grwth, Digital Signage Exp, Nv. 18, 2009, ArticleID/2249/reftab/67/t/Frecasts-Shw-Digital-Out-f-Hme-Still-n-Track-frGrwth/Default.aspx. 4 InfTrends Study Shws Strng Grwth Up Ahead fr Digital Signage, InfTrends, Jun. 6, 2007,

2 Until recently, a shrtcming f digital signage as an advertising medium was the challenge in determining hw many and what kind f individuals see a given display unit. This made it difficult fr advertisers t measure the size f their audience and price ad time n DOOH netwrks accrdingly. This prblem als makes it relatively difficult t target ads t specific audience demgraphics r psychgraphics, which is a crnerstne f mdern advertising. T vercme these bstacles, the DOOH industry is explring several technlgies that will imprve audience measurement and interactivity. Depending n the system, these enhancements ften btain a range f infrmatin abut cnsumers. Sme f the technlgies have the ability t identify individual cnsumers, track them as they mve frm place t place and stre detailed infrmatin abut their preferences and activities. These emerging technlgies include Facial recgnitin: Increasingly, DOOH units use facial measurement technlgy t discern certain characteristics abut a persn lking at the display. This is perhaps the mst cmmn methd, with ne cmpany claiming t have scanned 120 millin peple t date. 5 Sme systems, while nt yet cnfigured t identify individuals, can calculate a passerbyʼs age, gender, and race, and determine hw lng an individual watches the display. The advertisement n the screen can then change t match the cnsumerʼs prfile. Other systems nte nly gender, and still thers merely cunt the number f faces that see the screen (gazetracking). Mbile marketing: A rising number f DOOH units interact in varius ways with prtable devices, particularly mbile phnes. Sme units cmmunicate with phnes via SMS messaging and Bluetth t send rich cntent (like ringtnes r mvie trailers) t cnsumers. Other units enable cnsumers t dwnlad a cupn, play games, r enter cntests thrugh their mbile phnes. Given the brad range f ptential applicatins fr mbile marketing and DOOH, industry analysts predict the tw media will grw tgether. Scial netwrking: Sme DOOH units prvide access t scial netwrks like Facebk, Twitter and Flickr thrugh the Web r apps n cnsumersʼ mbile devices. In sme applicatins, cnsumers can send user-generated messages, phts and ther cntent t specific DOOH screen lcatins in real time. Sme lng-view predictins see cnsumers cnsulting friends abut clthing purchases thrugh retail-based DOOH screens ver scial netwrks. Radi Frequency Identificatin (RFID): The mst cmmn use f RFID in DOOH features RFID-enabled shelves that prmpt nearby digital signage units t display advertisements related t the prducts 5 Quividi, Autmated Audience Measurement, (last visited Jan. 3, 2010). 2

3 n the shelves. Other DOOH systems air ads triggered by shpper lyalty cards equipped with RFID. 6 License plate scanners: In a 2009 advertising pilt, digital billbards alng a UK highway displayed persnalized advertisements t passing cars. Radside cameras scanned license plates and ran the numbers thrugh the Driver and Vehicle Licensing Agency. The billbard then displayed the license number and the best type f mtr il fr that make and mdel f car. Public utrage and questins abut whether the piltʼs use f mtr vehicle registratin data fr marketing vilated UK privacy laws led t the piltʼs abrupt shutdwn. 7 DOOH uses ther technlgies, such as GPS, t a lesser extent, and mre have ptential t cmbine with DOOH t create interactive experiences fr cnsumers. Clearly DOOH can integrate many technlgies t cllect a brad range f cnsumer data in varius cntexts. Althugh the privacy recmmendatins in this dcument is intended t ffer suggestins fr present and future DOOH data cllectin practices, the significant innvatin DOOH has shwn in the past will likely lead t hithert unfreseen business mdels. The lng view: Behaviral advertising n the Internet f Things The Internet f Things has prfund implicatins fr ut-f-hme targeted marketing. Several sectrs are cnverging t encurage the grwth f pervasive cmputing, including DOOH, lcatin-based services, mbile payment systems, supply chain management, intelligent buildings and security. An extensive digital signage netwrk cmbined with ubiquitus bject tagging wuld enable advertisers t target persnalized, lcatin-based messages t individuals wherever they are. The Internet f Things is a term used t describe a cmputerized netwrk f physical bjects. 8 The netwrk wuld be supprted by an array f sensrs and data strage devices embedded in bjects, interacting with web services. 9 The 6 Clair Swedberg, French Jean Butique Adpts RFID t Bst Lyalty, RFID Jurnal, Jul. 11, 2007, 7 Christpher Leake, Driversʼ details sld by DVLA are used in bizarre radside adverts fr Castrl, Daily Mail, Sep. 27, 2009, /Nw-drivers-details-sld-DVLA-used-bizarre-radside-adverts-Castrl.html. 8 Fr a detailed discussin, see Intʼl Telecmm. Unin, ITU Internet Reprts 2005: The Internet f Things (7th ed. 2005). 9 One cmmnly referenced Internet f Things scenari envisins a refrigeratr that can mnitr the fd it stres. 9 The refrigeratr culd ntify the wner when fd spils, dwnlad recipes frm websites that make use f the fd in the fridge, ntify the wner f recalls frm the manufacturer, r ntify the wner f sales f fd he r she prefers. Several early versins f this appliance are ut n the market. See Richard MacManus, Internet Fridges: State f the Market, ReadWriteWeb, Jul. 28,

4 first generatin Internet f Things is being built n RFID tags and readers, and the related Near Field Cmmunicatin, but may als use Bluetth and ther technlgies that enable cmmunicatin at a distance. Because these technlgies reveal unique numbers r addresses t readers, they are easily assciated with the wners f the tagged bjects. Widely deplyed, this system wuld reveal vast amunts f data related t the tagged bjects, including lcatin infrmatin, envirnmental cnditins and prximity t ther bjects. Marketers, gvernment r researchers culd gather highly detailed data regarding an individualʼs activities, preferences and habits anywhere the individual ges, nt just when an individual is in frnt f a digital sign. 10 Data aggregatrs wuld be able t accumulate the varius pieces f data t create a unique prfile t serve targeted advertising as individuals passed a digital sign. An envirnment in which digital tags and readers are ubiquitus raises difficult issues f transparency, user cntrl ver data cllectin, lng-term prfiling and lcatin tracking. This dynamic is likely t blur the traditinal distinctin between privacy in the hme and utside the hme, particularly if husehld bjects relay data t third parties, which may necessitate a new thery f privacy that encmpasses bth the hme and public places. Even s, as a practical matter, privacy safeguards may be significantly mre difficult t implement n the massive scale that a pervasive system f tags, readers and advertising screens wuld require. The Internet f Things can bring numerus benefits, but unless careful attentin is paid t privacy as the system is being built, the Internet f Things can als create a sciety in which cnstant targeted advertising and gvernment surveillance diminish quality f life. This will take a cmmitment t privacy n the part f all the stakehlders in the Internet f Things, including the DOOH industry. The time is right fr a DOOH privacy framewrk Using identificatin and interactivity technlgies, the DOOH and mbile industries are taking the Internet experience int the physical wrld. In ding s, DOOH has established a burgening ffline versin f the behaviral advertising that currently ccurs nline the practice f tracking cnsumersʼ activities in rder t deliver advertising targeted t the individual interests. 11 Deplyed t enugh lcatins in digital signage units, such a practice may well be prfitable t the industry, just as behaviral advertising has prven prfitable n the Internet. 10 As example f an early pervasive tracking system, see the 2008 Cityware research prject. Researchers mnitred the Bluetth signals f hundreds f thusands f peple withut their knwledge in the UK twn f Bath. The researchers installed Bluetth signal receivers in pubs, ffices and ther public spaces and recrded the cllected infrmatin in a central database t study hw peple mve in the city. See Paul Lewis, Bluetth is watching: secret study gives Bath a flavur f Big Brther, The Guardian, Jul. 21, 2008, 11 Federal Trade Cmmissin, FTC Staff Reprt: Self-Regulatry Principles fr Online Behaviral Advertising, Pg. 2 (Feb. 2009), 4

5 Privacy invasin assciated with DOOH is nt rampant because nly a small percentage f digital signage units have audience measurement, identificatin r interactive capabilities. Hwever, the industry trend is clearly tward greater adptin f measurement, identificatin and surveillance capabilities, nt less. The usefulness f audience data t marketers and the increasing cst effectiveness f sphisticated equipment will encurage the DOOH industry t cllect detailed cnsumer data. Interactivity has been named a key driver f digital signage grwth in In January 2010, Intel and Micrsft annunced a jint effrt t develp DOOH that can emulate the ability f nline retailers t identify returning custmers and tailr advertisements t them based n their shpping histries. 13 Crdinating nline and ffline behaviral advertising will be especially natural t cmpanies like Fcus Media Hlding. Fcus Media wns an extensive Internet advertising netwrk and als perates the largest DOOH netwrk in China, with mre than 190,000 screens. 14 Cnsumers and cmpanies are already wary f the privacy implicatins f identificatin and cnsumer prfiling technlgies in DOOH. Cmments t blg psts and news articles n facial recgnitin in digital signage indicate many cnsumers have little faith that DOOH cmpanies will prtect cnsumer data. 15 Sme industry figures have said that cmpanies must guarantee cnsumer privacy, 16 while thers have cited privacy issues as an bstacle t using facial recgnitin technlgy fr advertising purpses. 17 A New Yrk Times article n billbards with facial recgnitin prmpted a majr DOOH cmpany t publicly defend its privacy practices. 18 Public backlash and pssible vilatins f existing 12 Capital Netwrkʼs Research Identifies Custmer Interactin as Key Digital Signage Trend fr 2010, Digital Signage Exp, Dec. 3, 2009, ArticleID/2312/reftab/66/Default.aspx. 13 Dn Clark and Nick Wingfield, Intel, Micrsft Offer Smart-Sign Technlgy, Wall Street Jurnal, Jan. 12, 2010, 14 Fcus Media, Cmpany Overview, (last visited Jan. 3, 2010). 15 Nilay Patel, TruMedia says its facial-recgnitin bilbards will never recrd vide, it wnʼt share with cps User Cmments, Engadget, Jun. 10, 2008, 16 Bill Gerpa, Digital signage netwrks must guarantee viewer privacy, The Digital Signage Insider, Aug. 1, 2008, es/digital_signage_netwrks_must_guarantee_viewer_privacy-569.html. 17 Digital Signage Exp, Questin f the mnth, Sep., 2009, 18 TruMedia: Facial Recgnitin Bards Will Never Recrd, Share Data, MediaBuyerPlanner, Jun. 11, 2008, 5

6 privacy laws have already led t the discntinuatin f sme DOOH advertising prjects, as with the billbard which scanned UK license plates. The reactin t smart signs parallels the cntrversy assciated with nline behaviral advertising. A 2009 study f cnsumer attitudes twards behaviral advertising fund tw-thirds f Americans definitely wuld nt allw marketers t track them nline, even if the tracking is annymus. 19 The study als fund 90% f yung adults reject advertising tailred t them based n ffline activities. Cnsumers repeatedly vice ppsitin t behaviral tracking fr nline advertising. Facebk users have revlted several times ver uses f their infrmatin n Facebk, persuading the scial netwrking site t repeatedly revise its privacy plicies and the infrmatin management tls it prvides t its users. 20 In 2009, the Federal Trade Cmmissin (FTC) issued self-regulatry guidelines fr nline behaviral advertising. 21 The sn-t-be Chairman stated the guidelines may be the last clear chance the industry had t shw it wuld effectively prtect cnsumer privacy in the absence f stricter legislatin. 22 Cngress has held multiple hearings n the issue, 23 and members f Cngress 19 Jseph Turw, Jennifer King, Chris Hfnagle, Amy Bleakly & Michael Hennessy, Cntrary t What Marketers Say, Americans Reject Tailred Advertising and Three Activities that Enable It, Pg. 3 (Sep. 29, 2009), 20 David Cursey, After Criticism, Facebk Tweaks Friends List Privacy Optins, PC Wrld, Dec. 10, 2009, friends_list_privacy_ptins.html?lmia_w=t0:s0:a41:g26:r32:c :b :z 0. See als Jessica Vascellar, Facebkʼs Abut-Face n Data, The Wall Street Jurnal, Feb. 19, 2009, See als, Juan Perez, Facebkʼs Beacn Mre Intrusive Than Previusly Thught, PC Wrld, Nv. 30, 2007, sly_thught.html. 21 Federal Trade Cmmissin, FTC Staff Reprt: Self-Regulatry Principles fr Online Behaviral Advertising, (Feb. 2009), 22 Id., Cncurring Statement f Jn Leibwitz, Chairman f the FTC, 23 Behaviral Advertising: Industry Practices and Cnsumersʼ Expectatins: Hearing befre the United States Huse f Representatives Cmmittee On Energy And Cmmerce Subcmm. On Cmmunicatins, Technlgy and the Internet and the Subcmm. On Cmmerce, Trade and Cnsumer Prtectin, 111th Cng., (Jun. 2009), :energy-and-cmmerce-subcmmittee-hearing-n-behaviral-advertising-industrypractices-and-cnsumers-expectatins&catid=122:media-advisries&itemid=55. 6

7 have repeatedly called fr privacy legislatin t regulate hw cnsumer infrmatin is cllected, used and shared fr nline marketing. 24 Given this envirnment, DOOH cmpanies shuld practively adapt their practices t be transparent and minimally intrusive, and t affrd cnsumers cntrl ver hw their infrmatin is cllected and used. Incrprating privacy int the fabric f DOOH business mdels and data management practices is the best way t prevent privacy risks befre they arise. 25 It will be less expensive fr DOOH cmpanies t integrate privacy cntrls nw, while identificatin technlgies are still relatively new t the industry, than it will be t retrfit privacy prtectins nt existing systems. Hw DOOH cmpanies handle the privacy issues they face tday will affect the way the public, regulatrs and advertisers perceive the industry, as well as the industryʼs directin in the future. The industry shuld prve its dedicatin t privacy prtectin t reduce the risk that the public will cnsider interactive DOOH a disrespectful intrusin. POPAI, a trade assciatin, recently released a first generatin set f privacy guidelines fr the industry. 26 POPAIʼs Cde f Cnduct is an excellent start fr industry self-regulatin. In particular, the Cdeʼs sectin n crss-channel and crss-dmain marketing cntains several gd privacy prtectins, such as the requirement that a cnsumer re-pt in each time he r she enters a new venue where crss-dmain marketing takes place. 27 Hwever, the Cde des nt articulate a full set f Fair Infrmatin Practices, nr des it suggest DOOH cmpanies establish a cmprehensive privacy framewrk. The POPAI Cde is a sund fundatin fr the DOOH industry, but the industry shuld nt limit itself t the Cdeʼs recmmendatins. Prtectin shuld g beynd directly identifiable infrmatin Sme privacy prtectin framewrks, including many industry guidelines, typically extend nly what was traditinally cnsidered persnally identifiable infrmatin (PII). PII was thught t include nly infrmatin that can be directly linked t an individualʼs identity. Hwever, it is increasingly being realized that the distinctin between PII and nn-pii is becming much less meaningful in light f data analytic capabilities. Researchers have demnstrated that individuals can 24 Rep. Rick Bucher, Behaviral ads: The need fr privacy prtectin, The Hill, (Sep. 24, 2009, 25 Fr mre detailed discussin f the Privacy By Design cncept, see Center fr Demcracy & Technlgy, The Rle f Privacy by Design in Prtecting Cnsumer Privacy, Dec. 21, 2009, 26 POPAI Digital Signage Grup, Best Practices: Recmmended Cde f Cnduct fr Cnsumer Tracking Research, (last visited Feb. 7, 2010). 27 See POPAI Cde, Pgs

8 still be identified frm recrds stripped f traditinal identifiers. 28 The FTC supprts extending privacy prtectin t infrmatin beynd that which nly directly identifies individuals. 29 Therefre, the best apprach fr cmpanies is t evaluate all the data they cllect n a spectrum ranging frm directly identifiable t pseudnymus t aggregated, prviding different levels f privacy prtectin crrespnding t the sensitivity f the infrmatin invlved. 30 Directly identifiable data includes what was nce referred t as PII: Name Address Telephne number Date f birth Scial Security Number Driverʼs license number License plate number address Bank, credit card, r ther accunt number Bimetric data, such as unique data pints captured via facial recgnitin systems Images f individuals. In additin t directly identifiable data, cmpanies shuld extend prtectin t any data that culd reasnably be assciated with a particular cnsumer r a particular cnsumerʼs prperty, such as a smart phne r ther device. 31 The term pseudnymus data refers t infrmatin assciated with a unique identifier. Althugh pseudnymus data des nt directly identify an individual, pseudnymus data can be traced t an individualʼs identity with relative ease. This type f data includes, but is nt limited t RFID cdes: RFID chips frequently cme with a uniquely identifiable number, which can individualize any prperty t which the chip is attached. Device identificatin numbers, such as IP address, Mac address, Bluetth number, Near Field Cmmunicatin number, Internatinal Mbile Equipment Identity number. 28 See Paul Ohm, Brken Prmises f Privacy: Respnding t the Surprising Failure f Annymizatin (August 2009), 29 Federal Trade Cmmissin, FTC Staff Reprt: Self-Regulatry Principles fr Online Behaviral Advertising, Pgs. iii, (Feb. 2009), 30 See Center fr Demcracy & Technlgy, Threshld Analysis fr Online Advertising Practices, Pg. 17 (Jan. 2009), 31 Federal Trade Cmmissin, FTC Staff Reprt: Self-Regulatry Principles fr Online Behaviral Advertising, Pgs (Feb. 2009), 8

9 Internet username, such as the name with which ne uses t psts t a discussin frum. Scial netwrking data, including lgin infrmatin and friend lists. User-generated data: data generated knwingly by an individual, such as search terms, psts in discussin frums and data input int scial netwrking prfiles. Whether a data element will reasnably identify an individual will depend n the cntext in which the data was cllected. When determining the privacy practices necessary fr handling pseudnymus data, cmpanies shuld cnsider the availability f ther data sets. 32 An individualʼs identity may be reasnably inferred by cmbining pseudnymus data with, fr example, recrds f purchases frm credit r lyalty cards, security surveillance systems, r aggregated lcatin data which reveals unique habits r travel patterns. Aggregate data includes infrmatin abut multiple individuals that cannt reasnably be used t directly identify r infer the identity f a single individual. The mst prminent example f this in DOOH may be facial qualificatin, where the demgraphics f individuals passing by a digital sign are cmpiled ver time, but unique bimetric data pints and images f individuals are nt saved. Even thugh aggregate data may nt be directly identifiable r re-identifiable, cmpanies shuld incrprate privacy practices particularly transparency int their cllectin f such data. Many cnsumers bject t cvert behaviral targeting even if it is dne n an annymus r aggregate basis. 33 Plicy Framewrk and Mdels Privacy standards fr DOOH shuld be based n the widely accepted Fair Infrmatin Practices (FIPs). These internatinally recgnized principles are reflected (althugh ften incmpletely) in many privacy laws in the U.S. and are als the basis f mre cmprehensive privacy laws internatinally, such as the Eurpean Uninʼs Data Prtectin Directive. Recently, the U.S. Department f Hmeland Security adpted a mdern and cmprehensive frmulatin f these principles. 34 CDT has recmmended DHSʼ frmulatin f the FIPs t the FTC as the basis fr addressing nline behaviral advertising, and we believe it is equally well-suited as the basis fr privacy guidelines fr the DOOH industry. These are the FIPs as set frth by DHS: Transparency 32 See, e.g., Bradley Malin and Latanya Sweeney, Hw (Nt) t Prtect Genmic Data Privacy in a Distributed Netwrk: Using Trail Re-identificatin t Evaluate and Design Annymity Prtectin Systems, Jurnal f Bimedical Infrmatics 37 (2004), Jseph Turw, Jennifer King, Chris Hfnagle, Amy Bleakly & Michael Hennessy, Cntrary t What Marketers Say, Americans Reject Tailred Advertising and Three Activities that Enable It, Pg. 3 (Sep. 29, 2009), 34 Department f Hmeland Security, The Fair Infrmatin Practice Principles: Framewrk fr Privacy Plicy at the Department f Hmeland Security (Dec. 2008), 9

10 Individual Participatin Purpse Specificatin Data Minimizatin Use Limitatin Data Quality and Integrity Security Accuntability The nline behaviral advertising industry has partially incrprated the FIPS int varius self-regulatry guidelines. These include the guidelines issued by the Netwrk Advertising Initiative and by the Interactive Advertising Bureau. Hwever, as CDT has pinted ut, the guidelines f the nline advertising industry fall shrt in key areas, s the DOOH industry shuld nt merely mimic them. 35 Nevertheless, the industries share the practice f targeting advertisements t cnsumers based n their activities. This makes it wrthwhile fr DOOH cmpanies t familiarize themselves with the privacy framewrks f their nline cunterparts. DOOH cmpanies and their affiliates may als find relevance in existing framewrks fr the technlgies they use. Fr example, DOOH cmpanies that utilize mbile marketing shuld use the Mbile Marketing Assciatin (MMA)ʼs Glbal Cde f Cnduct as a baseline n which t build. 36 Similarly, DOOH cmpanies that use RFID shuld integrate the standards f relevant trade assciatins r privacy grups. 37 Nne f these framewrks is perfect, and sme are deficient in certain areas, but they may serve as a starting pint fr cmpanies t develp their wn plicies. With reference t existing mdels, and drawing n the cmprehensive DHS framewrk, CDT recmmends that the DOOH industry develp a privacy framewrk alng the fllwing lines: 1) Transparency DOOH data cllectin and use shuld be transparent. Generally, there are tw imprtant ways fr DOOH cmpanies t d this. First, DOOH cmpanies shuld develp privacy plicies and publish them n their websites. Secnd, DOOH cmpanies shuld give cnsumers ntice at the lcatin in which the DOOH unit is placed. Transparency thrugh ntice and a public privacy plicy is the 35 Center fr Demcracy & Technlgy, Online Behaviral Advertising: Industry's Current Self-regulatry Framewrk is Necessary, But Still Insufficient On Its Own t Prtect Cnsumers, Dec. 7, 2009, 36 Mbile Marketing Assciatin, Glbal Cde f Cnduct (Jul. 2008), 37 Center fr Demcracy & Technlgy Wrking Grup n RFID, Privacy Best Practices fr Deplyment f RFID Technlgy, May 1, 2006, See als Electrnic Privacy Infrmatin Center, Guidelines n Cmmercial Use f RFID Technlgy, Jul. 9, 2004, 10

11 respnsibility f nt just the technlgy vendrs, which are unfamiliar t cnsumers, but als the digital signage netwrk peratrs and the wners f the establishments at which the signage is lcated. a) Privacy Plicies Privacy plicies serve an imprtant rle. Internally, the prcess f develping a privacy plicy frces a cmpany t assess its data cllectin practices and develp rules fr the custdianship f the data it cllects. A privacy plicy shuld describe in cncise, specific terms What cnsumer data is cllected, Hw the data is cllected, The purpses fr which the data is used, With whm the data is shared, Hw the data is prtected, Hw lng the data is retained, and The chices that cnsumers have with respect t their data. Once the plicy is set, data shuld nt be cllected, shared r used in any way cntrary t the published privacy plicy. 38 In sme cases, the data management practices f the DOOH cmpany may verlap with the practices f anther cmpany, such as when DOOH integrates with mbile marketing r scial netwrking applicatins. The DOOH privacy plicy shuld underscre hw these services interact. Numerus DOOH cmpanies already publish privacy plicies. Fr example, sme f the plicies f cmpanies using facial recgnitin state they d nt retain images r identify individuals. 39 Similarly, sme cmpanies that integrate digital signage and scial netwrking publish privacy plicies. 40 Hwever, existing plicies vary greatly in detail, and nt all DOOH services specify what they d with persnal infrmatin. 41 A privacy plicy alne is nt enugh, hwever, and 38 The FTC cnsiders a material vilatin f a published privacy plicy t cnstitute an unfair and deceptive trade practice prhibited under the Federal Trade Cmmissin Act. 15 U.S.C. 45(a)(2). See als Mark Fley, The FTCʼs Web Site Privacy and Security Rules fr Every Business, Wiscnsin Lawyer, (Mar. 2008), tentdisplay.cfm&cntentid= Cgnvisin, Privacy Plicy, Sep., 2007, 40 LcaMda, Privacy Plicy, (last visited Jan. 3, 2010). 41 See e.g., The Marketplace Statin, Privacy Plicy, (last visited Feb. 7, 2010). The plicy makes n reference f the data cllectin systems integrated int sme f Marketplace Statinʼs screens. See Cgnvisin integrates with BradSign fr autmated digital signage campaign analytics, Digital Signage Tday, Apr. 17, 2009, 11

12 many cnsumers cnfuse the mere existence f a plicy with substantive privacy prtectins. 42 b) Ntice At present, mst DOOH cmpanies are cmpletely unknwn t cnsumers, s cnsumers are unlikely t lk fr the privacy plicies psted n the websites f DOOH cmpanies. Even if cnsumers cme t knw the names f DOOH cmpanies, current practices give cnsumers little hint as t what cmpany is respnsible fr a given DOOH display. The challenge fr the industry is t find a way t present meaningful ntice at the pint f data cllectin. Such ntice is fundamental t transparency and individual participatin. Cnsumers shuld be given clear, prminent ntice f DOOH media units that cllect cnsumer data at the physical lcatin in which the unit perates. T the extent pssible, the ntice shuld appear cnspicuusly n r clse t each DOOH unit that is cllecting the infrmatin. 43 One ntice shuld nt cver, fr example, an entire supermarket, but instead shuld be at each sensr and assciated DOOH screen within the supermarket. There shuld be n hidden receivers, cameras r sensrs used exclusively fr marketing. Generic ntices like These premises are under vide surveillance are nt sufficient. Cnsumers have cme t assume such ntices t relate t security measures, nt marketing. Such ntices d nt prvide accurate ntificatin f the mre cmprehensive data cllectin, sharing and usage assciated with marketing. If a DOOH unit is used fr bth security and fr marketing, r if security infrmatin is used fr marketing, the ntice (and privacy plicy) shuld clearly disclse this. CDT cnceptualizes three tiers f ntice. At minimum, DOOH cmpanies culd adpt a symbl t place n signage units, such as n a small placard r appearing n the screen alngside cntent. The symbl shuld identify the unit as ne that cllects sme frm f cnsumer data. This apprach wrks best if the symbl is adpted n an industry-wide basis and tested t ensure real cnsumers understand what it means. The nline behaviral advertising industry is adpting this apprach. Many nline ads that use demgraphic and behaviral data will include a certain symbl and phrases like Why did I get this ad?. An Internet user wh clicks the symbl r phrase will receive an explanatin f the hw the ad was targeted t him r her. 44 Similarly, if DOOH units include nly 42 Jseph Turw, Chris Hfnagle, Deirdre Mulligan, Nathaniel Gd, Jens Grssklags, The FTC and Cnsumer Privacy in the Cming Decade, Pg. 2 (Nv. 8, 2006), 43 The POPAI Cde permits ne ntice t cver ne establishment. See POPAI Cde f Cnduct, Pg. 8. Hwever, CDT believes a ntice shuld be prvided at each screen. One discreet ntice in an islated lcatin within a large retail stre full f labels cmpeting fr cnsumersʼ attentin is insufficient t prvide ntice fr a DOOH netwrk cllecting data thrughut the stre. 44 Stephanie Cliffrd, A Little ʻiʼ t Teach Abut Online Privacy, New Yrk Times, January 26, 2010, 12

13 symbls as ntice, a cmprehensive ntice shuld als be placed elsewhere in the establishment. The secnd tier f ntice that culd be placed n the DOOH unit wuld identify the cmpany wh wns r perates the unit, infrm cnsumers f what infrmatin is being cllected. Again, there shuld be a cmprehensive ntice elsewhere in the establishment. The third tier is a cmprehensive ntice that includes the abve infrmatin, and als the purpses fr which the infrmatin is being used, with whm the infrmatin is shared, what ther cnsumer data will be cmbined with the infrmatin and, if applicable, the chices cnsumers have with respect t the infrmatin being cllected. In cases where DOOH units interact with cnsumersʼ devices, such as with smart phnes via Bluetth, a cmprehensive ntice shuld als be delivered directly t the cnsumersʼ devices. This shuld be the nrm when the DOOH unit r the cnsumer initiates the interactin. 2) Individual Participatin The FIPs principle f individual participatin embdies tw cncepts: the right t cnsent t the cllectin and use f data and the right t access t data that has been cllected abut neself. The rbustness f the individual participatin prtcl required varies depending n the sensitivity and identifiability f the infrmatin cllected and the use t which it is put. Similarly t the POPAI Cde, CDT cnceptualizes DOOH audience measurement and interactive marketing as ccurring n general three levels: Level I: Audience cunting. Infrmatin related t cnsumers is gathered n an aggregate basis and nt used fr tailring advertisements. N retained infrmatin, including images, links t individuals r their prperty. Example: facial recgnitin systems that track gazes r recrd passerby demgraphics, but d nt stre facial images r cntextualize ads. Level II: Audience targeting. Infrmatin related t cnsumers is cllected n an aggregate basis and is used fr tailring cntextual advertisements t individuals. N retained infrmatin, including images, links t individuals r their prperty. Example: facial recgnitin systems that recrd passerby demgraphics and cntextualize ads accrdingly. Level III: Audience identificatin and/r prfiling. Infrmatin related t cnsumers is cllected n an individual and aggregate basis and is used fr tailring advertisements. Infrmatin linked t individual identity r an individualʼs prperty (such as a mbile phne) is retained. Example: using DOOH netwrks fr scial netwrking, RFID tracking, mbile marketing. a) Cnsent 13

14 Cnsumers shuld have a ready means t chse whether their data is cllected fr advertising purpses. The means will differ between DOOH systems and services. Levels I and II shuld implement pt-ut cnsent. At minimum, pt-ut cnsent can be accmplished via ntice by giving cnsumers an pprtunity t avid a particular DOOH unit. Level III requires pt-in cnsent, which shuld be issued after the cnsumer has the pprtunity t examine the applicable privacy plicy. Cnsumers shuld be able t exercise cntrl ver what infrmatin is cllected, which marketing messages they receive, and which ther cmpanies and parties may see the data. The cnsent shuld be persistently hnred until the cnsumer alters his r her chice, and the cnsent shuld als be revcable at any time. T the extent pssible, pt-in cnsent prtcl shuld be granular withut als being cnfusing t cnsumers. One way t strike this balance is t ffer varius privacy cntrl ptins, but t als ffer an easy means t pt-ut r pt-in t all the chices at nce. b) Access Cnsumers shuld have the ability t view and crrect any directly identifiable data cllected abut them fr DOOH marketing. Cnsumer cnfidence in an rganizatin may be vastly imprved if individuals have access t their wn data, whereas cnsumers will perceive surveillance and data analysis behind clsed drs as cnsiderably mre intrusive. 3) Purpse Specificatin, The purpse specificatin principle requires a cmpany t think thrugh its data cllectin and use practices and t specify hw the cmpany intends t use the data it is cllecting. The purpses t which cnsumer data will be put shuld be nly specified nt later than at the time f cllectin. Prperly applied, the principle shuld lead cmpanies t minimize the cllectin f unnecessary data, which is the next principle. 4) Data Minimizatin Thrugh privacy plicies and guidelines, individual cmpanies and the DOOH industry as a whle shuld cmmit t limit their data cllectin and retentin t nly the minimum necessary t achieve specified ends. DOOH cmpanies shuld cllect and use the minimum amunt f cnsumer data necessary t deliver their services. Fr example, there is n need t use a license plate number when a carʼs make and mdel will d. 45 In mst cases, it may nt be necessary t retain cnsumer data fr future use beynd the delivery f a cntextual advertising message. Fr example, there is n need t maintain persistent recrds f phne numbers r Bluetth addresses when a cmpany 45 Christpher Leake, Driversʼ details sld by DVLA are used in bizarre radside adverts fr Castrl, Daily Mail, Sep. 27, 2009, /Nw-drivers-details-sld-DVLA-used-bizarre-radside-adverts-Castrl.html. 14

15 des nt seek an nging relatinship with the individuals assciated with that data. When a DOOH cmpany des retain cnsumer infrmatin, that retentin shuld last n lnger than is needed t serve the purpse fr which it was cllected, as specified in the privacy plicy. 46 If a cnsumer pts-ut r cancels a service, the assciated infrmatin shuld be destryed. 5) Use Limitatin Cnsumer data shuld nt be shared fr any uses that are incmpatible with the purpses specified in the cmpanyʼs privacy plicy. Transfers f cnsumer data t any third parties r affiliates shuld be transparent, specified in advance t cnsumers and may require pt-in cnsent. 47 6) Data Quality & Integrity DOOH cmpanies shuld, t the extent practicable, ensure cnsumer data they cllect is accurate, relevant, timely and cmplete. Allwing cnsumers t access and edit data cllected abut them is ne f the best mechanisms fr ensuring data quality and integrity. 7) Security DOOH cmpanies shuld exercise reasnable and apprpriate effrts t secure infrmatin cllected abut cnsumers. In s ding, a cmpany shuld maintain a standard infrmatin security prgram apprpriate t the amunt and sensitivity f the infrmatin stred n its system. Such a security prgram shuld include prcesses t identify and address reasnably freseeable internal and external risks t the security, cnfidentiality, and integrity f infrmatin. The nature and extent f security required will largely depend n what kind f cllectin technlgy is emplyed and what cnsumer data is retained. Unnecessary cnsumer data shuld be destryed via secure methdlgies. The best data security is fr a cmpany nt t pssess cnsumer data in the first place. 8) Accuntability There has been substantial criticism f self-regulatin f the behaviral advertising industry because f a lack f accuntability fr nncmpliance. DOOH cmpanies wh cllect and use cnsumersʼ infrmatin shuld establish internal accuntability mechanisms. These mechanisms shuld ensure strict cmpliance with cmpaniesʼ privacy plicies, as well as laws and ther applicable privacy prtectin requirements. Cmpanies shuld prvide privacy and security training t all emplyees, cntractrs and affiliates wh cllect and 46 The POPAI Cde recmmends that image r bimetric data shuld be stred fr up t 3 mnths r the maximum perid allwed by law. See POPAI Cde f Cnduct, Pg. 6. It is unclear whether POPAI means that the data shuld be stred n lnger than that perid, r whether POPAI recmmends that the data be stred regardless f whether there is a business need fr it, s lng as the law allws it. 47 See POPAI Cde f Cnduct, Pgs

16 use cnsumersʼ infrmatin. There shuld be meaningful penalties fr vilatins, especially willful r chrnic nncmpliance. The DOOH industry may als cnsider empwering ne r mre trade assciatins with independent versight functins t mnitr cmpliance and ffer privacy management guidance fr individual cmpanies. The rganizatin that takes n these functins shuld prvide a dispute reslutin frum fr cnsumers and articulate clear benchmarks fr cmpanies t evaluate the efficacy f their privacy practices. Fr mre infrmatin, please cntact Harley Geiger Staff Attrney, CDT x 316 CDT wishes t thank Melissa Ng f Privacy Lives (www.privacylives.cm) fr her cnsultatin and cntributins t this reprt. 16

DIGITAL SIGNAGE FEDERATION Digital Signage Privacy Standards. February 2011

DIGITAL SIGNAGE FEDERATION Digital Signage Privacy Standards. February 2011 DIGITAL SIGNAGE FEDERATION Digital Signage Privacy Standards February 2011 Intrductin Interactivity and cnsumer engagement are pised t be key drivers f grwth fr the digital signage industry. Thrugh technlgies

More information

A Framework for Digital Signage Privacy

A Framework for Digital Signage Privacy March 1, 2010 A Framewrk fr Digital Signage Privacy Intrductin Digital Out-Of-Hme (DOOH), als knwn as digital signage r smart signs, is a cmmunicatins medium characterized by a dynamic display presenting

More information

Key Steps for Organizations in Responding to Privacy Breaches

Key Steps for Organizations in Responding to Privacy Breaches Key Steps fr Organizatins in Respnding t Privacy Breaches Purpse The purpse f this dcument is t prvide guidance t private sectr rganizatins, bth small and large, when a privacy breach ccurs. Organizatins

More information

First Global Data Corp.

First Global Data Corp. First Glbal Data Crp. Privacy Plicy As f February 23, 2015 Ding business with First Glbal Data Crp. ("First Glbal", First Glbal Mney, "we" r "us", which includes First Glbal Data Crp. s subsidiary, First

More information

What Information Is Collected and How Is It Collected?

What Information Is Collected and How Is It Collected? RCI PRIVACY NOTICE RCI Pacific Pty Ltd is cncerned abut privacy issues and wants yu t be familiar with hw we cllect, use and disclse infrmatin. This Privacy Ntice describes ur practices in cnnectin with

More information

PRIVACY POLICY Last revised: April 2015

PRIVACY POLICY Last revised: April 2015 PRIVACY POLICY Last revised: April 2015 ACD, LLC, and its affiliates (cllectively, we, us, ur ) understand that privacy is imprtant t ur cnsumers and want yu t make knwledgeable decisins abut the infrmatin

More information

Research Report. Abstract: The Emerging Intersection Between Big Data and Security Analytics. November 2012

Research Report. Abstract: The Emerging Intersection Between Big Data and Security Analytics. November 2012 Research Reprt Abstract: The Emerging Intersectin Between Big Data and Security Analytics By Jn Oltsik, Senir Principal Analyst With Jennifer Gahm Nvember 2012 2012 by The Enterprise Strategy Grup, Inc.

More information

Privacy Policy. The Central Equity Group understands how highly people value the protection of their privacy.

Privacy Policy. The Central Equity Group understands how highly people value the protection of their privacy. Privacy Plicy The Central Equity Grup understands hw highly peple value the prtectin f their privacy. Fr that reasn, the Central Equity Grup takes particular care in dealing with any persnal and sensitive

More information

CRM and Social Media: Maximizing Deeper Customer Relationships

CRM and Social Media: Maximizing Deeper Customer Relationships Seattle Office: 2211 Ellitt Avenue Suite 200 Seattle, Washingtn, 98121 seattle@avanade.cm www.avanade.cm A glbal IT cnsultancy dedicated t using the Micrsft platfrm t help enterprises achieve prfitable

More information

Data Protection Act Data security breach management

Data Protection Act Data security breach management Data Prtectin Act Data security breach management The seventh data prtectin principle requires that rganisatins prcessing persnal data take apprpriate measures against unauthrised r unlawful prcessing

More information

Change Management Process

Change Management Process Change Management Prcess B1.10 Change Management Prcess 1. Intrductin This plicy utlines [Yur Cmpany] s apprach t managing change within the rganisatin. All changes in strategy, activities and prcesses

More information

University of Texas at Dallas Policy for Accepting Credit Card and Electronic Payments

University of Texas at Dallas Policy for Accepting Credit Card and Electronic Payments University f Texas at Dallas Plicy fr Accepting Credit Card and Electrnic Payments Cntents: Purpse Applicability Plicy Statement Respnsibilities f a Merchant Department Prcess t Becme a Merchant Department

More information

Data Protection Policy & Procedure

Data Protection Policy & Procedure Data Prtectin Plicy & Prcedure Page 1 Prcnnect Marketing Data Prtectin Plicy V1.2 Data prtectin plicy Cntext and verview Key details Plicy prepared by: Adam Haycck Apprved by bard / management n: 01/01/2015

More information

The Importance Advanced Data Collection System Maintenance. Berry Drijsen Global Service Business Manager. knowledge to shape your future

The Importance Advanced Data Collection System Maintenance. Berry Drijsen Global Service Business Manager. knowledge to shape your future The Imprtance Advanced Data Cllectin System Maintenance Berry Drijsen Glbal Service Business Manager WHITE PAPER knwledge t shape yur future The Imprtance Advanced Data Cllectin System Maintenance Cntents

More information

VCU Payment Card Policy

VCU Payment Card Policy VCU Payment Card Plicy Plicy Type: Administrative Respnsible Office: Treasury Services Initial Plicy Apprved: 12/05/2013 Current Revisin Apprved: 12/05/2013 Plicy Statement and Purpse The purpse f this

More information

UNIVERSITY OF CALIFORNIA MERCED PERFORMANCE MANAGEMENT GUIDELINES

UNIVERSITY OF CALIFORNIA MERCED PERFORMANCE MANAGEMENT GUIDELINES UNIVERSITY OF CALIFORNIA MERCED PERFORMANCE MANAGEMENT GUIDELINES REFERENCES AND RELATED POLICIES A. UC PPSM 2 -Definitin f Terms B. UC PPSM 12 -Nndiscriminatin in Emplyment C. UC PPSM 14 -Affirmative

More information

In addition to assisting with the disaster planning process, it is hoped this document will also::

In addition to assisting with the disaster planning process, it is hoped this document will also:: First Step f a Disaster Recver Analysis: Knwing What Yu Have and Hw t Get t it Ntes abut using this dcument: This free tl is ffered as a guide and starting pint. It is des nt cver all pssible business

More information

WHAT YOU NEED TO KNOW ABOUT. Protecting your Privacy

WHAT YOU NEED TO KNOW ABOUT. Protecting your Privacy WHAT YOU NEED TO KNOW ABOUT Prtecting yur Privacy YOUR PRIVACY IS OUR PRIORITY Credit unins have a histry f respecting the privacy f ur members and custmers. Yur Bard f Directrs has adpted the Credit Unin

More information

The Importance of Market Research

The Importance of Market Research The Imprtance f Market Research 1. What is market research? Successful businesses have extensive knwledge f their custmers and their cmpetitrs. Market research is the prcess f gathering infrmatin which

More information

CMS Eligibility Requirements Checklist for MSSP ACO Participation

CMS Eligibility Requirements Checklist for MSSP ACO Participation ATTACHMENT 1 CMS Eligibility Requirements Checklist fr MSSP ACO Participatin 1. General Eligibility Requirements ACO participants wrk tgether t manage and crdinate care fr Medicare fee-fr-service beneficiaries.

More information

COMPREHENSIVE SAFETY ASSESSMENT INSTRUCTIONS for STUDY ABROAD PROGRAMS

COMPREHENSIVE SAFETY ASSESSMENT INSTRUCTIONS for STUDY ABROAD PROGRAMS COMPREHENSIVE SAFETY ASSESSMENT INSTRUCTIONS fr STUDY ABROAD PROGRAMS Belw is a list f items t address and questins that need t be addressed in the cmprehensive safety assessment. In additin t the safety

More information

UNIVERSAL MUSIC GROUP PRIVACY POLICY. Universal Music AB ("We") are committed to protecting and respecting your privacy.

UNIVERSAL MUSIC GROUP PRIVACY POLICY. Universal Music AB (We) are committed to protecting and respecting your privacy. Effective Date: 2016-04-26 UNIVERSAL MUSIC GROUP PRIVACY POLICY Universal Music AB ("We") are cmmitted t prtecting and respecting yur privacy. This privacy plicy (tgether with ur terms f use and any ther

More information

THE CITY UNIVERSITY OF NEW YORK IDENTITY THEFT PREVENTION PROGRAM

THE CITY UNIVERSITY OF NEW YORK IDENTITY THEFT PREVENTION PROGRAM THE CITY UNIVERSITY OF NEW YORK IDENTITY THEFT PREVENTION PROGRAM 1. Prgram Adptin The City University f New Yrk (the "University") develped this Identity Theft Preventin Prgram (the "Prgram") pursuant

More information

We will record and prepare documents based off the information presented

We will record and prepare documents based off the information presented Dear Client: We appreciate the pprtunity f wrking with yu regarding yur Payrll needs. T ensure a cmplete understanding between us, we are setting frth the pertinent infrmatin abut the services that we

More information

Network Security Trends in the Era of Cloud and Mobile Computing

Network Security Trends in the Era of Cloud and Mobile Computing Research Reprt Abstract: Netwrk Security Trends in the Era f Clud and Mbile Cmputing By Jn Oltsik, Senir Principal Analyst and Bill Lundell, Senir Research Analyst With Jennifer Gahm, Senir Prject Manager

More information

Research Report. Abstract: Advanced Malware Detection and Protection Trends. September 2013

Research Report. Abstract: Advanced Malware Detection and Protection Trends. September 2013 Research Reprt Abstract: Advanced Malware Detectin and Prtectin Trends By Jn Oltsik, Senir Principal Analyst With Jennifer Gahm, Senir Prject Manager September 2013 2013 by The Enterprise Strategy Grup,

More information

Disk Redundancy (RAID)

Disk Redundancy (RAID) A Primer fr Business Dvana s Primers fr Business series are a set f shrt papers r guides intended fr business decisin makers, wh feel they are being bmbarded with terms and want t understand a cmplex tpic.

More information

Social Media Policy. Record Number D14/78. Director Business Support and Strategy Manager Customer and Communications. Responsible Manager

Social Media Policy. Record Number D14/78. Director Business Support and Strategy Manager Customer and Communications. Responsible Manager Scial Media Plicy Scial Media Plicy Recrd Number D14/78 Respnsible Manager Directr Business Supprt and Strategy Manager Custmer and Cmmunicatins Last reviewed 11 February 2014 Adptin reference Cuncil Reslutin

More information

Internet and Social Media Solicitations: Wise Giving Tips

Internet and Social Media Solicitations: Wise Giving Tips Internet and Scial Media Slicitatins: Wise Giving Tips Charities use a wide variety f methds t slicit charitable dnatins. New and pwerful technlgies utilize nt just the internet and email, but als scial

More information

Cornwall Partners in Care

Cornwall Partners in Care Crnwall Partners in Care Mving Frward Versin 2.0 8 th January 2014 By Richard Mnk Crnwall Partners in Care August 2013 Page 1 f 6 CPIC mving frward This dcument has been created t help prvide a little

More information

Aim The aim of a communication plan states the overall goal of the communication effort.

Aim The aim of a communication plan states the overall goal of the communication effort. Develping a Cmmunicatin Plan- Aim Aim The aim f a cmmunicatin plan states the verall gal f the cmmunicatin effrt. Determining the Aim Ask yurself r yur team what the verall gal f the cmmunicatin plan is.

More information

Access EEC s Web Applications... 2 View Messages from EEC... 3 Sign In as a Returning User... 3

Access EEC s Web Applications... 2 View Messages from EEC... 3 Sign In as a Returning User... 3 EEC Single Sign In (SSI) Applicatin The EEC Single Sign In (SSI) Single Sign In (SSI) is the secure, nline applicatin that cntrls access t all f the Department f Early Educatin and Care (EEC) web applicatins.

More information

Social Media Security Awareness for Business or Home Computing Users

Social Media Security Awareness for Business or Home Computing Users Scial Media Security Awareness fr Business r Hme Cmputing Users The purpse f all scial media sites, whether fr business r persnal use, is cmmunicatin, sharing, and smetimes cllabratin. The benefits f the

More information

Succession Planning & Leadership Development: Your Utility s Bridge to the Future

Succession Planning & Leadership Development: Your Utility s Bridge to the Future Successin Planning & Leadership Develpment: Yur Utility s Bridge t the Future Richard L. Gerstberger, P.E. TAP Resurce Develpment Grup, Inc. 4625 West 32 nd Ave Denver, CO 80212 ABSTRACT A few years ag,

More information

FundingEdge. Guide to Business Cash Advance & Bank Statement Loan Programs

FundingEdge. Guide to Business Cash Advance & Bank Statement Loan Programs Guide t Business Cash Advance & Bank Statement Lan Prgrams Cash Advances: $2,500 - $1,000,000 Business Bank Statement Lans: $5,000 - $500,000 Canada Cash Advances: $5,000 - $500,000 (must have 9 mnths

More information

Privacy Policy Statement

Privacy Policy Statement Last revised: July, 2015 Privacy Plicy Statement The Clrx Cmpany (cllectively, we, us, ur ) prvide this Privacy Plicy Statement ( Privacy Statement ) t infrm yu f ur practices regarding the cllectin, use

More information

Army DCIPS Employee Self-Report of Accomplishments Overview Revised July 2012

Army DCIPS Employee Self-Report of Accomplishments Overview Revised July 2012 Army DCIPS Emplyee Self-Reprt f Accmplishments Overview Revised July 2012 Table f Cntents Self-Reprt f Accmplishments Overview... 3 Understanding the Emplyee Self-Reprt f Accmplishments... 3 Thinking Abut

More information

Guidelines for Custodians

Guidelines for Custodians Guidelines fr Custdians t assess cmpliance with the Persnal Health Infrmatin Privacy and Access Act (PHIPAA) This dcument is designed t help custdians evaluate readiness fr cmpliance with PHIPAA and t

More information

Plus500CY Ltd. Statement on Privacy and Cookie Policy

Plus500CY Ltd. Statement on Privacy and Cookie Policy Plus500CY Ltd. Statement n Privacy and Ckie Plicy Statement n Privacy and Ckie Plicy This website is perated by Plus500CY Ltd. ("we, us r ur"). It is ur plicy t respect the cnfidentiality f infrmatin and

More information

Internet and E-Mail Policy User s Guide

Internet and E-Mail Policy User s Guide Internet and E-Mail Plicy User s Guide Versin 2.2 supprting partnership in mental health Internet and E-Mail Plicy User s Guide Ver. 2.2-1/5 Intrductin Health and Scial Care requires a great deal f cmmunicatin

More information

Risk Management Policy AGL Energy Limited

Risk Management Policy AGL Energy Limited Risk Management Plicy AGL Energy Limited AUGUST 2014 Table f Cntents 1. Abut this Dcument... 2 2. Plicy Statement... 2 3. Purpse... 2 4. AGL Risk Cntext... 3 5. Scpe... 3 6. Objectives... 3 7. Accuntabilities...

More information

Defining Sales Campaign Automation How e-mail, the Killer App, is best applied to marketing

Defining Sales Campaign Automation How e-mail, the Killer App, is best applied to marketing Defining Sales Campaign Autmatin Hw e-mail, the Killer App, is best applied t marketing Summary: Cmpanies tday are steadily adpting strategies and technlgies t reach prspects, custmers, and partners thrugh

More information

Best Practices on Monitoring Hotel Review Sites By Max Starkov and Mariana Mechoso Safer

Best Practices on Monitoring Hotel Review Sites By Max Starkov and Mariana Mechoso Safer January 2008 Best Practices n Mnitring Htel Review Sites By Max Starkv and Mariana Mechs Safer Hteliers ften ask HeBS hw they can mnitr the Internet chatter surrunding their htels and whether r nt they

More information

Patient Participation Report

Patient Participation Report Patient Participatin Reprt In 2011, Westngrve Partnership decided t establish a PPG (Patient Participatin Grup) that wuld allw us t engage with ur patients, receive feedback frm them and ensure that they

More information

MANITOBA SECURITIES COMMISSION STRATEGIC PLAN 2013-2016

MANITOBA SECURITIES COMMISSION STRATEGIC PLAN 2013-2016 MANITOBA SECURITIES COMMISSION STRATEGIC PLAN 2013-2016 The Manitba Securities Cmmissin (the Cmmissin) is a divisin f the Manitba Financial Services Agency (MFSA). The ther divisin is the Financial Institutins

More information

Electronic Signatures Overview

Electronic Signatures Overview White Paper Electrnic Signatures Overview Versin 1.0 Last Updated: 20-09-2010 www.sutisft.cm Histry f Electrnic Signatures Over 100 years ag, peple were using Mrse cde and the telegraph t electrnically

More information

DALBAR Due Diligence: Trust, but Verify

DALBAR Due Diligence: Trust, but Verify BEST INTEREST INVESTMENT RECOMMENDATIONS Advisr Rle under Best Interest Regulatins January 27, 2016 In the era when the cntractual bligatin is t act in the client s best interest, investment decisins can

More information

Improved Data Center Power Consumption and Streamlining Management in Windows Server 2008 R2 with SP1

Improved Data Center Power Consumption and Streamlining Management in Windows Server 2008 R2 with SP1 Imprved Data Center Pwer Cnsumptin and Streamlining Management in Windws Server 2008 R2 with SP1 Disclaimer The infrmatin cntained in this dcument represents the current view f Micrsft Crpratin n the issues

More information

AMWA Chapter Subgroups on LinkedIn Guidance for Subgroup Managers and Chapter Leaders, updated 2-12-15

AMWA Chapter Subgroups on LinkedIn Guidance for Subgroup Managers and Chapter Leaders, updated 2-12-15 AMWA Chapter Subgrups n LinkedIn Guidance fr Subgrup Managers and Chapter Leaders, updated 2-12-15 1. Chapters may nt have an independent grup n LinkedIn, Facebk, r ther scial netwrking site. AMWA prvides

More information

COPIES-F.Y.I., INC. Policies and Procedures Data Security Policy

COPIES-F.Y.I., INC. Policies and Procedures Data Security Policy COPIES-F.Y.I., INC. Plicies and Prcedures Data Security Plicy Page 2 f 7 Preamble Mst f Cpies FYI, Incrprated financial, administrative, research, and clinical systems are accessible thrugh the campus

More information

Business Plan 2014-15

Business Plan 2014-15 Cmmissin fr Lcal Administratin in England Business Plan 2014-15 All Business Plan activity is linked t ur fur Strategic Objectives LGO Business Plan 2014-2015 v web 3 Page 1 descriptin 1. Prvide a cmplaints

More information

HIPAA HITECH ACT Compliance, Review and Training Services

HIPAA HITECH ACT Compliance, Review and Training Services Cmpliance, Review and Training Services Risk Assessment and Risk Mitigatin: The first and mst imprtant step is t undertake a hlistic risk assessment that examines the risks and cntrls related t fur critical

More information

CONTENTS UNDERSTANDING PPACA. Implications of PPACA Relative to Student Athletes. Institution Level Discussion/Decisions.

CONTENTS UNDERSTANDING PPACA. Implications of PPACA Relative to Student Athletes. Institution Level Discussion/Decisions. This dcument is intended t prvide NCAA member institutins with an infrmatinal guide regarding the ptential implicatins f the Patient Prtectin and Affrdable Care Act f 2010 (PPACA) when fully implemented

More information

CCHIIM ICD-10 Continuing Education Requirements for AHIMA Certified Professionals (& Frequently Asked Questions for Recertification)

CCHIIM ICD-10 Continuing Education Requirements for AHIMA Certified Professionals (& Frequently Asked Questions for Recertification) CCHIIM ICD-10 Cntinuing Educatin Requirements fr AHIMA Certified Prfessinals (& Frequently Asked Questins fr Recertificatin) The transitin t ICD-10-CM and ICD-10-PCS is anticipated t imprve the capture

More information

BEST PRACTICES IN DELIVERING SUPERIOR CUSTOMER INTERACTIONS

BEST PRACTICES IN DELIVERING SUPERIOR CUSTOMER INTERACTIONS BEST PRACTICES IN DELIVERING SUPERIOR CUSTOMER INTERACTIONS IMPROVING THE CUSTOMER EXPERIENCE IN TODAY S CONTACT CENTER SUMMARY At the heart f delivering exceptinal custmer experience is hw each interactin

More information

Multi-Year Accessibility Policy and Plan for NSF Canada and NSF International Strategic Registrations Canada Company, 2014-2021

Multi-Year Accessibility Policy and Plan for NSF Canada and NSF International Strategic Registrations Canada Company, 2014-2021 Multi-Year Accessibility Plicy and Plan fr NSF Canada and NSF Internatinal Strategic Registratins Canada Cmpany, 2014-2021 This 2014-21 accessibility plan utlines the plicies and actins that NSF Canada

More information

Research Report. Abstract: Security Management and Operations: Changes on the Horizon. July 2012

Research Report. Abstract: Security Management and Operations: Changes on the Horizon. July 2012 Research Reprt Abstract: Security Management and Operatins: Changes n the Hrizn By Jn Oltsik, Senir Principal Analyst With Kristine Ka and Jennifer Gahm July 2012 2012, The Enterprise Strategy Grup, Inc.

More information

Group 3 Flip Chart Notes

Group 3 Flip Chart Notes MDH-DLI Sympsium -- Meeting Mandates, Making the Cnnectin: Wrkers Cmpensatin Electrnic Health Care Transactins -- Nvember 5, 2014 Grup 3 Flip Chart Ntes Meeting Mandates, Making the Cnnectin: Wrkers Cmpensatin

More information

DisplayNote Technologies Limited Data Protection Policy July 2014

DisplayNote Technologies Limited Data Protection Policy July 2014 DisplayNte Technlgies Limited Data Prtectin Plicy July 2014 1. Intrductin This dcument sets ut the bligatins f DisplayNte Technlgies Limited ( the Cmpany ) with regard t data prtectin and the rights f

More information

Colorado Rapids Youth Soccer Club Social Media and Electronic Communication Policies

Colorado Rapids Youth Soccer Club Social Media and Electronic Communication Policies Clrad Rapids Yuth Sccer Club Scial Media and Electrnic Cmmunicatin Plicies OVERVIEW Online, scial media and ther electrnic cmmunicatin tls such as text messaging have becme a prevalent and effective means

More information

Process of Setting up a New Merchant Account

Process of Setting up a New Merchant Account Prcess f Setting up a New Merchant Accunt Table f Cntents PCI DSS... 3 Wh t cntact?... 3 Bakcgrund n PCI... 3 Why cmply?... 3 Hw t cmply?... 3 PCI DSS Scpe... 4 Des PCI DSS Apply t Me?... 4 What if I am

More information

A. Early Case Assessment

A. Early Case Assessment Electrnic Discvery Reference Mdel Standards fr the identificatin f electrnically stred infrmatin in discvery http://www.edrm.net/resurces/standards/identificatin A. Early Case Assessment Once a triggering

More information

How Checking Accounts Work

How Checking Accounts Work Hw Checking Accunts Wrk LESSON PREPARATION AND TEACHER INFORMATION Lessn Summary: This lessn is intended fr high schl students during a frty minute time perid. The lessn teaches students the purpse f a

More information

Corporate Standards for data quality and the collation of data for external presentation

Corporate Standards for data quality and the collation of data for external presentation The University f Kent Crprate Standards fr data quality and the cllatin f data fr external presentatin This paper intrduces a set f standards with the aim f safeguarding the University s psitin in published

More information

Virtual Meetings and Virtual Teams Using Technology to Work Smarter

Virtual Meetings and Virtual Teams Using Technology to Work Smarter http://www.psu.edu/president/pia/innvatin/ INNOVATION INSIGHT SERIES NUMBER 9 Virtual Meetings and Virtual Teams Using Technlgy t Wrk Smarter Yu need t have a meeting. Sme f the peple yu d like t include

More information

Creating an Ethical Culture and Protecting Your Bottom Line:

Creating an Ethical Culture and Protecting Your Bottom Line: Creating an Ethical Culture and Prtecting Yur Bttm Line: Best Practices fr Crprate Cdes f Cnduct Nte: The infrmatin belw and all infrmatin n this website is nt meant t be taken as legal advice. Please

More information

CCHIIM ICD-10 Continuing Education Requirements for AHIMA Certified Professionals (& Frequently Asked Questions for Recertification)

CCHIIM ICD-10 Continuing Education Requirements for AHIMA Certified Professionals (& Frequently Asked Questions for Recertification) CCHIIM ICD-10 Cntinuing Educatin Requirements fr AHIMA Certified Prfessinals (& Frequently Asked Questins fr Recertificatin) The transitin t ICD-10-CM and ICD-10-PCS is anticipated t imprve the capture

More information

Implementing an electronic document and records management system using SharePoint 7

Implementing an electronic document and records management system using SharePoint 7 Reprt title Agenda item Implementing an electrnic dcument and recrds management system using SharePint 7 Meeting Finance, Prcurement & Prperty Cmmittee 16 June 2008 Date Reprt by Dcument Number Head f

More information

Personal Data Security Breach Management Policy

Personal Data Security Breach Management Policy Persnal Data Security Breach Management Plicy 1.0 Purpse The Data Prtectin Acts 1988 and 2003 impse bligatins n data cntrllers in Western Care Assciatin t prcess persnal data entrusted t them in a manner

More information

Professional Leaders/Specialists

Professional Leaders/Specialists Psitin Prfile Psitin Lcatin Reprting t Jb family Band BI/Infrmatin Manager Wellingtn Prfessinal Leaders/Specialists Band I Date February 2013 1. POSITION PURPOSE The purpse f this psitin is t: Lead and

More information

WHAT SHOULD I LOOK FOR WHEN I BUY HEALTH INSURANCE?

WHAT SHOULD I LOOK FOR WHEN I BUY HEALTH INSURANCE? WHAT SHOULD I LOOK FOR WHEN I BUY HEALTH INSURANCE? The Maine Bureau f Insurance 34 State Huse Statin Augusta, Maine 04333 207-624-8475 r 1-800-300-5000 (in Maine) http://www.maine.gv/pfr/insurance Paul

More information

Magenta HR in partnership with breath ehr

Magenta HR in partnership with breath ehr BREATHEHR ONLINE HR SYSTEM AND PORTAL Magenta HR in partnership with breath ehr Magenta HR Cnsulting Ltd. 24 Canning Street, Edinburgh EH3 8EG Tel. 0131 2272769 www.magentahr.cm inf@magentahr.cm 6 December

More information

FINANCIAL SERVICES FLASH REPORT

FINANCIAL SERVICES FLASH REPORT FINANCIAL SERVICES FLASH REPORT Draft Regulatry Cmpliance Management Guideline Released by the Office f the Superintendent f Financial Institutins May 5, 2014 On April 30, 2014, the Office f the Superintendent

More information

The Cost Benefits of the Cloud are More About Real Estate Than IT

The Cost Benefits of the Cloud are More About Real Estate Than IT y The Cst Benefits f the Clud are Mre Abut Real Estate Than IT #$#%&'()*( An Osterman Research Executive Brief Published December 2010 "#$#%&'()*( Osterman Research, Inc. P.O. Bx 1058 Black Diamnd, Washingtn

More information

Entrepreneur Purchasing Recommendations for CRM

Entrepreneur Purchasing Recommendations for CRM Entrepreneur Purchasing Recmmendatins fr CRM Salesbm.cm Mst business wners wuld tend t agree that they dn't necessarily think f themselves as entrepreneurs, they are just peple running a business, making

More information

UNITED STATES OF AMERICA FEDERAL ENERGY REGULATORY COMMISSION. Statement of Thomas F. O Brien. Vice President & Chief Information Officer

UNITED STATES OF AMERICA FEDERAL ENERGY REGULATORY COMMISSION. Statement of Thomas F. O Brien. Vice President & Chief Information Officer UNITED STATES OF AMERICA FEDERAL ENERGY REGULATORY COMMISSION Revised Critical Infrastructure Prtectin Reliability Standards Dcket N. RM15-14-000 Statement f Thmas F. O Brien Vice President & Chief Infrmatin

More information

Getting Started Guide

Getting Started Guide AnswerDash Resurces http://answerdash.cm Cntextual help fr sales and supprt Getting Started Guide AnswerDash is cmmitted t helping yu achieve yur larger business gals. The utlined pre-launch cnsideratins

More information

Equal Pay Audit 2014 Summary

Equal Pay Audit 2014 Summary Equal Pay Audit 2014 Summary Abut the dcument The fllwing summary is an abridged versin f Ofcm s equal pay audit 2014. In the full versin f the reprt we set ut ur key findings, cmment n any issues arising

More information

Using PayPal Website Payments Pro UK with ProductCart

Using PayPal Website Payments Pro UK with ProductCart Using PayPal Website Payments Pr UK with PrductCart Overview... 2 Abut PayPal Website Payments Pr & Express Checkut... 2 What is Website Payments Pr?... 2 Website Payments Pr and Website Payments Standard...

More information

AuditNet Survey of Bring your own Device (BYOD) - Control, Risk and Audit

AuditNet Survey of Bring your own Device (BYOD) - Control, Risk and Audit AuditNet Survey f Bring yur wn Device (BYOD) - Cntrl, Risk and Audit The pace f technlgy mves much faster than managers and auditrs can understand and react, with updated plicies, prcedures and cntrls.

More information

Job Profile Data & Reporting Analyst (Grant Fund)

Job Profile Data & Reporting Analyst (Grant Fund) Jb Prfile Data & Reprting Analyst (Grant Fund) Directrate Lcatin Reprts t Hurs Finance Slihull Finance Directr Nminally 37 hurs but peratinally available at all times t meet Cmpany requirements Cntract

More information

CONSTRUCTION INDUSTRIES & MANUFACTURED HOUSING DIVISION

CONSTRUCTION INDUSTRIES & MANUFACTURED HOUSING DIVISION New Mexic Regulatin and Licensing Department 2550 Cerrills Rad Santa Fe, NM 87505 Ph (505) 476-4700 Fax (505) 476-4685 INSTRUCTIONS FOR FILING A COMPLAINT Thank yu fr cntacting The New Mexic Regulatin

More information

Phi Kappa Sigma International Fraternity Insurance Billing Methodology

Phi Kappa Sigma International Fraternity Insurance Billing Methodology Phi Kappa Sigma Internatinal Fraternity Insurance Billing Methdlgy The Phi Kappa Sigma Internatinal Fraternity Executive Bard implres each chapter t thrughly review the attached methdlgy and plan nw t

More information

Employees - recruitment, records and monitoring

Employees - recruitment, records and monitoring Emplyees - recruitment, recrds and mnitring This guidance has been prduced t help rganisatins cmply with the Data Prtectin Act (DPA) when recruiting and emplying wrkers. It is relevant t public sectr emplyers,

More information

Oakland Unified School District Impact Assessment Performance Management in Action

Oakland Unified School District Impact Assessment Performance Management in Action Oakland Unified Schl District Impact Assessment Perfrmance Management in Actin The perfrmance management system that has been built in this district prvides the systems that supprt ur cmmitment t scial

More information

Version Date Comments / Changes 1.0 January 2015 Initial Policy Released

Version Date Comments / Changes 1.0 January 2015 Initial Policy Released Page 1 f 6 Vice President, Infrmatics and Transfrmatin Supprt APPROVED (S) REVISED / REVIEWED SUMMARY Versin Date Cmments / Changes 1.0 Initial Plicy Released INTENT / PURPOSE The Infrmatin and Data Gvernance

More information

Montana Acquisition & Contracting System (emacs) emacs Handbook. Vendor Registration and Data Management

Montana Acquisition & Contracting System (emacs) emacs Handbook. Vendor Registration and Data Management Mntana Acquisitin & Cntracting System (emacs) emacs Handbk Vendr Registratin and Data Management Welcme The purpse f this emacs Handbk fr Vendr Registratin and Data Management is t prvide vendrs with the

More information

FORM ADV (Paper Version) UNIFORM APPLICATION FOR INVESTMENT ADVISER REGISTRATION AND REPORT FORM BY EXEMPT REPORTING ADVISERS

FORM ADV (Paper Version) UNIFORM APPLICATION FOR INVESTMENT ADVISER REGISTRATION AND REPORT FORM BY EXEMPT REPORTING ADVISERS APPENDIX A FORM ADV (Paper Versin) UNIFORM APPLICATION FOR INVESTMENT ADVISER REGISTRATION AND REPORT FORM BY EXEMPT REPORTING ADVISERS Frm ADV: General Instructins Read these instructins carefully befre

More information

HIPAA Notice of Privacy Practices. Central Ohio Surgical Associates, Inc.

HIPAA Notice of Privacy Practices. Central Ohio Surgical Associates, Inc. HIPAA Ntice f Privacy Practices Central Ohi Surgical Assciates, Inc. THIS NOTICE OF PRIVACY PRACTICES (THE NOTICE ) DESCRIBES HOW HEALTH INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN

More information

Research Report. Abstract: Data Center Networking Trends. January 2012. By Jon Oltsik With Bob Laliberte and Bill Lundell

Research Report. Abstract: Data Center Networking Trends. January 2012. By Jon Oltsik With Bob Laliberte and Bill Lundell Research Reprt Abstract: Data Center Netwrking Trends By Jn Oltsik With Bb Laliberte and Bill Lundell January 2012 2012 Enterprise Strategy Grup, Inc. All Rights Reserved. Intrductin Research Objective

More information

By offering the Study Abroad Scholarship, we hope to make your study abroad experience much more affordable!

By offering the Study Abroad Scholarship, we hope to make your study abroad experience much more affordable! Internatinal Educatin Prgrams is pleased t annunce a Study Abrad Schlarship fr Seattle Central Cmmunity Cllege students. The schlarship has been established by the Internatinal Educatin Prgrams divisin

More information

Privacy Policy. What personally identifying information is collected on or through the Frames Data Online Site?

Privacy Policy. What personally identifying information is collected on or through the Frames Data Online Site? Privacy Plicy Welcme t www.framesdata.cm! This site (the Frames Data Online Site ) is wned by Frames Data Inc. ("FDI" r we ), a subsidiary f Jbsn Medical Infrmatin LLC ("JMI") and its parent, Jbsn Healthcare

More information

WEBSITE PRIVACY NOTICE

WEBSITE PRIVACY NOTICE WEBSITE PRIVACY NOTICE Last updated and effective as f July 31, 2015 Welcme t the Negen family f websites, which includes, amng thers, www.negen.cm and rder.negen.cm (each a Site and cllectively, the Sites

More information

CDC UNIFIED PROCESS PRACTICES GUIDE

CDC UNIFIED PROCESS PRACTICES GUIDE Dcument Purpse The purpse f this dcument is t prvide guidance n the practice f Risk Management and t describe the practice verview, requirements, best practices, activities, and key terms related t these

More information

366 Degrees Gaining Extra Degrees of Success

366 Degrees Gaining Extra Degrees of Success 366 Degrees Gaining Extra Degrees f Success In the rush t gain new custmers, cmpanies ften verlk their best custmers the nes they already have. While finding and attracting new custmers is certainly fundamental

More information