How can consumers opt out of cross-device tracking if they don’t even know it exists?
“When people are surprised, that can have negative consequences on trust, a brand and enforcement,” FTC commissioner Terrell McSweeney said to a crowd of 150 people in the advertising community – many of them lawyers – at the Digital Advertising Alliance Summit (DAA) in New York City on Tuesday. “I think the consumer education piece is critical.”
The DAA, responsible for the AdChoices icon that allows users to opt out of the interest-based advertising, is figuring out how to address consumer choice around mobile.
After the DAA releases a mobile opt-out for online behavioral advertising on September 1st, it will turn its attention to how to give consumers choice around cross-device tracking.
“We’re hoping self-regulatory bodies can help us,” said Tapad’s VP and general manager Vivian Chang, who said it’s a problem that consumers don’t know what cross-device tracking is.
The FTC, which is holding an event on cross-device tracking this November, is also causing the DAA to accelerate its self-regulation work around cross-device.
In a series of panels at the DAA summit, participants touched on what responsible use of cross-device tracking technology might look like, as well as the options for opt-outs.
Nick Nyham, CEO of the WPP Data Alliance, said that while he wouldn’t want a targeted ad every time he passed a store, he was okay with that geolocation data being stored for an ad at a later time. The idea is to make more efficient advertising. “We can walk this line well if it feels like fewer, better ads that are multichannel,” Nyham said.
The DAA doesn’t believe location data should be categorized as PII. But along with health data, it’s being considered sensitive, recognizable information it’s being considered sensitive, recognizable information in a data security breach notification act currently in the House of Representatives. That would mean an app that just had its location data hacked would have to notify the FTC, something that seems like overkill to the DAA and Stu Ingis, partner at the law firm Venable.
The DAA thinks about cross-device technology in terms of levels of transparency, Ingis told AdExchanger.
For instance, it’s debating whether a cross-device tracking option should be centralized or if different opt-outs should apply for individual ads, as in AdChoices.
The more granular the opt-out mechanism gets, the more complicated the logistics. How could a consumer un-link a device that doesn’t belong to the user? What if the user wants to de-link one device and keep the rest connected?
Additionally, what will an opt-out icon even look like on a small screen?
“A lot of our expression of consumer choice has to do with an icon in the ad,” said Ziff Davis CEO Vivek Shah, a publisher and buyer in the space. “It will be difficult for the [mobile] format to carry that icon. We have to get to a point where can I express choice across all areas of advertising.”
Even as adoption of cross-device technology brings it to the attention of the FTC and DAA, there’s still plenty below the tip of the iceberg.
Panels throughout the conference emphasized the need to consider privacy and opt-out mechanisms from the beginning. Sheila Colclasure, the public policy and privacy officer for Axciom, said the company thinks about these principles when dealing with “edge of the knife” situations, where policy is miles away.
The FTC agrees. “What’s gratifying to see is how seriously companies are taking on these issues and making good choices [around] security by design and privacy by design,” McSweeney said. “It’s trying to incorporate someone who understands those principles early enough that they’re incorporated, and it’s not a top-down lawyering at the end. I think people are getting that.”
