Big announcement today: advertising industry groups have come together to announce a set of principles for enhanced consumer disclosure and choice in behavioral data collection about consumers. At the heart of the proposal is a requirement that robust disclosures and opt-out processes be distributed across all of the individual web sites and web pages where consumer behavioral information is collected. This disclosure must happen in one of two ways: (1) through a link in the advertisement itself or in close proximity to it, or (2) through a link elsewhere on the page where data is collected, which takes the user to a list of networks collecting consumer information and links to pages that explain their data collection practices.
The first approach, while easy for any individual ad network to implement, is likely to be unappealing to ad networks and advertisers, since it takes up valuable real estate and competes with the ad’s message. Disclosure in the advertisement also is wholly unworkable from a consumer point of view — a concerned consumer would have to pay attention to all of the ads that appear on pages they view and click through to their individual disclosures, which is hardly practicable given that there are hundreds of ad networks collecting user information across sites.
The second approach to disclosure, while not as prominent, is much more workable from a consumer point of view. Anyone interested in data collection practices can click from any page on a website to a complete list of the networks who collect data on the site, read the relevant policies and avail themselves of opt-out capabilities if so desired. Under the second approach the work falls to the website using ad networks; they must provide their own customized list of ad partners and links. Is that workable?
The answer is yes, and we’ve already already built it.
Privacychoice for Websites, now available in beta, is a turn-key solution that any website can implement in minutes, without compiling their own list of collecting companies or links to privacy disclosures. Instead, our spider regularly samples pages on their site, determines which companies are collecting information through their pages, and creates a consolidated summary of the privacy practices of all those companies, with links to each network’s privacy disclosures and opt-out process. Over 500 top websites are already in our system, and we’re adding scores of new sites every day. Any participating site need only claim their profile and place a links to it throughout their site (relatively easy to do with style sheets).
For an example, take a look at the privacychoice highlights page for the NY Post website, which is distinguished by the sheer number of third-party companies who collect information there (over 25 at last count), based on ads and tags we found on the site. As you can see, our summary hits the major disclosure topics described in the new policies: whether the user remains anonymous, when information is shared with non-affiliates, whether sensitive information may be collected, and how long user information is retained. As our beta program proceeds, we will be fine tuning the disclosure to even more closely track the policy guidelines.
The privacychoice service not only provides turn-key compliance with the new advertising principles, it addresses these additional key concerns:
It isn’t just about ad networks. Although it is great to see the ad industry coalescing on disclosure practices, consumer data collection is not just about advertising. Scores of other companies, such as content delivery networks, analytics providers and audience measurement firms collect information about consumers across websites, and the lines between these different purposes are becoming more blurred. The data collection, use and retention practices of these other companies are also important to consumers, and in many cases they provide opt-outs that should be easily available.
Web publishers are responsible, too. We provide the website operator with an alert when we find new companies collecting information on their sites. With the growth of ad exchanges and optimization firms that take ads on the fly from any number of networks, responsible web publishers should be aware of what third-party data collection practices are happening on their sites, even if they are selling advertising through intermediaries. This kind of visibility also helps bring the industry toward best practices even faster, since web site publishers are the ones enabling data collection in the first place.
Choices must be persistent. Through privacychoice.org, we have provided an initial version of the privacychoice browser add-on for Firefox, and have served over 850,000 opt-outs to date. Over time, our plan is to integrate browser-based settings with choices presented on each website’s privacychoice summary, so that opt-out decisions are persistent even when cookies are deleted.
It should be independent. Voluntary cooperation among leading ad networks is great to see, but it isn’t realistic to think the every ad network will quickly comply with the new principles. By providing an independent determination of the third-party data collection policies applicable to each website, our solution shines a light on networks who aren’t in compliance, providing even greater consumer confidence.
We’re excited to see that the beta version of our service comes so close to the new disclosure approach now being embraced by the ad industry. Now we need your input and comments as we refine the service, and of course we’re happy to add your website to our database. In either case, please send us a note.