I just came across Mastercard’s site, which provides users with the ability to opt out of the aggregation and analysis of their behavioral data. This is interesting not only because it’s an opt-out within a single site (usually we only see them for data collected across sites), but also because of how it is implemented. Mastercard seems to store the opt-out preference via a Flash cookie (local stored object).
Of course, as discussed in prior posts, this is the most durable approach for consumers. My comments filed for the upcoming FTC Roundtable suggested that, at the very least, tracking companies should maintain proportionality between the methods they use to gather information and the methods they use to signify the opt-out; which is to say: if a tracking company gathers user information via Flash cookies, then their opt-out mechanism should use Flash cookies as well.
Mastercard’s opt-out is also interesting as part of a larger trend: more and more individual companies and advertisers — and not just ad networks — are starting to collect deeper behavioral information within their own sites and across websites where they advertise. While it is good that many of these companies recognize the need to offer enhanced disclosure and choice, implementing and managing opt-outs is becoming much more difficult. Any serious industry effort aimed at consumer choice will not expect average users to decipher this on an ad-by-ad basis. A truly usable disclosure and choice platform will provide aggregation, both at the website level and across tracking companies based on policy patterns and certifications.