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Friday, January 11, 2008

On-Site Behavioural Targeting and Consumer Privacy

In the US, the FTC recently published proposals for self-regulation in the behaviourally targeted advertising industry. We welcome moves towards protecting consumer privacy online and feel that a self-regulatory approach underpins the professionalism of our discipline.

Although the some of the principals published for the regulations are intended to govern cross-domain use of behavioural data primarily in the case of advertising networks, they also apply to our work providing people with more relevant and appropriate user experiences online.

Behavioural targeting has been a major part of offline business since the very beginning of the post-industrial era (queue the Ford Model T cliché). Online, our interest in user behaviour information is as a means to mathematically improve relevance and service.

By knowing the on-site content most effective at converting past visitors, we can make statistical conclusions about its relevance to future visitors with the same traits. These traits could include details of the referring site and other demographic details but we don’t process anything personally identifiable.

Robust opt-out mechanisms will provide reassurance to those concerned about online privacy and we believe that self-regulation is an important step towards protecting all consumers from any less than scrupulous operators.

In Europe, the IAB is leading the development of a set of guidelines covering best practice for the promotion and trading of behaviourally targeted media. Their standpoint on privacy issues is that current EU ecommerce and data protection directives cover this to an adequate extent.

We would support this view as behavioural targeting on-site does not leverage any personally identifiable data into the equation and this is one of the main precepts for data protection and privacy concerns to kick in. We acknowledge that there are new privacy concerns raised by behavioural targeting, particularly where behavioural data is shared across domains or in-depth “anonymous” profiles might become personally identifiable to some extent due to the nature of search terms recorded.

We would welcome a similar self-regulatory system in the UK to maintain good practice in this respect and ensure privacy is protected online.

The proposed US guidelines (60KB PDF Document)