I’m here at the FTC’s Privacy Roundtable. It’s a who’s who of the online privacy space. A well-timed report from the CDT today gives BetterAdvertising a nice compliment:
There has been some encouraging work by companies in the compliance area to address some of these concerns. For example, see Better Advertising
It was in a footnote on page 17 of the report, and it was in the context of this paragraph:
“The FTC Principles only require advertisers to state that personal data is being collected and to state that consumers can opt-out of data collection.43 The Privacy Group Coalitionʼs disclosure requirement is similar; the Coalitionʼs Legislative Primer suggests that an entity engaged in behavioral targeting “must have a publicly available privacy policy that describes its practices and policies with respect to the collection, maintenance, use, and disclosure of information about an individual used for behavioral targeting.”44 The NAI and IAB both require that disclosures outline the type of data to be collected, how the data will be used or transferred, and a link to a mechanism for exercising control over data collection. The IAB disclosure also must list which PII is being collected,45 while the NAI requires that members list additional information on their Web sites, including the length of the data retention period and the types of PII and non-PII that will be merged.46 CDT is encouraged by the NAI and IABʼs disclosure requirements, but the key questions are whether they will be comprehensively implemented by the end of the year deadline, and whether or not they will be interpreted by members as requiring the comprehensive disclosure of individual companies responsible for tracking. Multiple companies are typically involved in the targeting of a particular ad, including the advertiser in the case of retargeting, data aggregators providing data to the advertiser directly or through demand-side platforms or ad exchanges, and then downstream ad networks that use behavioral data to optimize audience as the ad is relayed to the consumer. Any solution that elects one of these constituents to be identified in notice to the exclusion of others should be viewed as inadequate.47“
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[47] There has been some encouraging work by companies in the compliance area to address some of these concerns. For example, see Better Advertising
Tags: Behavioral Advertising, CDT, Center for Democracy and Technology, Federal Trade Commission, FTC, Self-Regulation
