FTC Commissioner Thomas Rosch Reflections on Behavioral Advertising
In his speech to the US Chamber of Commerce, FTC Commissioner Thomas Rosch provides an interesting analysis of the Commission’s legal authority in the area of online behavioral advertising. He calls non-personal behavioral tracking a “vexing” policy issue, but suggests that there are ” some hard legal issues that need to be resolved even if one thinks, as a policy matter, that undisclosed online behavioral tracking should be prohibited”.
Consumers need to understand more about what is being done online. The understanding will breed trust, and the trust will breed a more viable advertising solution.
We agree with Jeff Hirsch, CEO of AudienceScience. But talk is cheap. Will industry really seek to deliver on user trust? We hope so but we also think that many aren’t yet engaged in the hard work needed to move the online ad system in the right direction. In addition to FPF’s ongoing efforts involving consumer testing of the best words and symbols to educate users about online personalization, this process requires serious effort to fix the broken opt-out process, to define which sensitive profiling categories should be restricted and to set maximum retention times for clickstream profiles. And let’s not forget giving users accesss to their profile requests.
We created a leading practices gallery to highlight leaders in offering consumers transparency and genuine choice. Unfortunately too many are sitting back, waiting for the problem to go away.
"We just connect"
Steve Lohr’s “Bits” column in The NY Times today gave us a chuckle. A senior official at Adchemy, a privately held online marketing company, said this about his firm’s expertise in “statistical personalization”:
“We don’t hold any data. We just connect to 30 or 40 data sources,” Mr.Nukala said.
Businesses today should be seeking to support their data use by being accountable, transparent and putting users in control. But this comment reminded us of the late Sen. Russell Long’s old saying: Don’t look at you, don’t look at me, look at the fellow behind the tree.
Update from the UK:The Department for Energy and Climate Change (DECC) expressed privacy concerns within its impact assessment, stating that there “is theoretically scope…for using the smart metering communications infrastructure to enable a variety of other services, such as monitoring of vulnerable householders by health authorities or social services.”
“Information from smart meters could also make it possible for a supplier to determine when electricity or gas was being used in a property and, to a degree, the types of technology that were being used within the property,” the assessment reads. “This could be used to target energy efficiency advice and offers of measures, social programmes etc. to householders.”
Europe and Online Profiling…
The Council of Europe proposes rules for online profiling and wants your opinion.
53 Billion Euro in Savings Possible from Deployment of Smart Meters in the EU – If Utilities Control Your Power Usage.
The Brattle Group, a leading consultancy with a focus on the smart grid, recently issued a *report* (expiered)
stating the following:
“Quantifying and stressing the environmental benefits of dynamic tariffs, ensuring transparent and adequate financial rewards and offering customers a lower flat tariff in return for providing “automatic” demand response could help boost customer participation.”
— this means the utility must understand and directly help control your power usage for the maximum savings, for you and them. Just giving consumers pricing and usage information doesn’t provide the maximum savings and puts a management burden on them. But, will consumers trust their utility enough? Only if privacy of their data and the appliances they use at home is handled very very wisely!
Michelle Dennedy, chief governance officer, cloud computing at Sun Microsystems.Ms. Dennedy is an expert in designing policies that foster trust in cloud environments. Formerly Sun’s chief privacy officer, she has overseen the development of data privacy policies that comport with international data regulations.
Lorrie Faith Cranor, associate professor of computer science and engineering at Carnegie Mellon University. The author of more than 80 research papers on issues such as online privacy, phishing, spam, anonymous publishing, and usable access control, Ms. Cranor is director of Carnegie Mellon’s CyLab Usable Privacy and Security Laboratory (CUPS).
Andy Holleman, chief privacy officer at Qwest Communications. Mr. Holleman has been providing integral counsel to Qwest on privacy issues since 2001. As the company’s CPO, his work includes policy formation, the development and delivery of privacy training, and providing privacy-related advice on new products and services, among several other tasks.
We are honored and delighted that these prominent experts would serve on FPF’s Advisory Board.
The Unruly Advertising Ecosystem
Kudos to Harvard Asst professor Ben Edelman, for his latest expose of the underbelly of the online advertising environment. Edelman, an FPF Advisory Board member, has been a long time critic of ad networks or advertisers that don’t do enough to control where their ads are placed. At www.Benedelman.org, he has documented ads showing up in adware, spyware, porn sites and other unsavory locations. Here he shows how advertisers themselves are ripped off when their ad networks place ads on invisible, non-existent web sites. No one ever sees the ads, but the advertisers pay-up.
Until advertisers and publishers reclaim their relationships with web surfers, and press their ad partners to do the hard work to support the needed improvements in the areas of privacy, security, and quality, these are the kinds of exposes that are likely to keep on coming.
