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On Tuesday, January 28th, the Wall Street Journal posted an article focused on the release of an IAB paper “Privacy and Tracking in a Post-Cookie World.” The story on originally contained three errors related to fundamental aspects of the IAB’s membership, technical ramifications of described technology and the nature of the document discussing current technological alternatives to the cookie. We appreciate the Journal’s willingness to make those fixes resulting in a decidedly more accurate representation of the IAB and the digital advertising industry. However, I would still like to address a few instances of language selection that could be easily misinterpreted by an average reader.


First, I would like to explain what a cookie is and how it works, since the description in the Wall Street Journal wasn’t on the mark.

The IAB’s Wiki calls it “a string of text from a web server to a user’s browser that the browser is expected to send back to the web server in subsequent interactions.” Yes, the cookie is also the means by which tracking and preference management happens today in digital advertising, but “code” is another word for software that implies active functionality. As anyone familiar with web or internet technology knows, a cookie is just a marker like a security badge (the analogy given in our whitepaper) or a supermarket customer loyalty card.

Second, within the article, there is an implication that client-generated state management (device IDs) could consolidate online tracking in the hands of specific vendors.

In fact those vendors would only control the underlying mechanism that creates the IDs and not the nature of the way those IDs are used by the industry. This is equivalent to saying that the phone company has control over your supermarket loyalty program data because in that case the ID is your phone number. In fact, within this particular solution class, we have seen two very privacy-centric implementations by Apple and Google in their respective mobile operating systems.

The third potential misinterpretation comes from the statement that device IDs solve the problem of cross device tracking.

Since client-generated state is created within a specific operating environment (such as a device operating system or a browser) it does not enable cross-device tracking. In fact, no current implementations of client-generated state allow automatic industry-wide cross-browser or cross-device tracking. This can and should only ever be possible at the bequest of the user.

Lastly, the cloud solution class described in the document is meant to be a connector between different state management technologies, not a warehouse of personal data, as asserted in the article. 

In fact, the cloud technology envisioned in the whitepaper could become the technology that enables a user to synchronize their advertising preferences across devices and domains. 

In fairness to the journalist, I recognize that this is rather technical for a general business audience. But, we at the IAB feel it is important to accurately represent technology and prevent the perpetuation of misunderstanding for the purpose of easy readability.

About the Author

Steve-Sullivan-headshot.pngSteve Sullivan 

Steve Sullivan is VP of Advertising Technology at the IAB, and on Twitter at @SteveSullivan32.

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Privacy advocates and regulators have challenged the ad industry to provide meaningful choice when it comes to the collection and use of behavioral data. In response, industry leaders have come together in support of the enhanced ad notice icon, which leads the user to industry wide disclosure and choice options. Although some still question this approach, it is well positioned to have significant industry adoption as a framework for consumer choice on traditional websites.

PrivacyChoice_Policymaker.jpgThe industry is at an earlier stage when it comes to providing notice and choice on mobile devices. The infrastructure delivering mobile ads isn’t as well developed, and the ecosystem is more complex with carriers, devices and operating systems each playing a role. Nevertheless, given the rapid growth expected for mobile advertising, and the heightened privacy concerns associated with location-aware mobile devices, it is imperative that we also focus on how to deliver meaningful choice in this new environment.

The in-ad use of the enhanced ad notice icon faces some obstacles when applied to ads that appear within mobile apps, a growing segment of online ads. Not only does there tend to be less visible real estate in mobile ads, there’s no easy way (like cookies) to store the preference so that it is accessible across or between different apps and the mobile browser. Companies are working on ways to store tracking preferences at the device-level, but to work this will take a new level of cooperation between advertisers, operating system providers, and app makers—each with their own privacy agenda.

Despite these challenges, meaningful choice may actually become easier for ads in mobile apps because they can provide a different choice framework. Unlike typical websites, every app already has a moment of choice before any data collection begins: the moment of installation. Users typically install new apps through a marketplace (like Apple’s App Store) where they search, browse, and select new apps. Each app has a reference page, which can include links to terms of service and privacy information. Notice-and-choice for tracking, possibly even the icon itself, can be provided at this stage in the process of installing an application.

Is it asking too much of mobile app makers to create appropriately titled links and a privacy policy with the right disclosure? In fact, privacy policies are already required of websites under the laws of many states. Even though a minority of apps have a published privacy policy, that can change as privacy disclosure becomes easier and more automated. For example, we recently launched PrivacyChoice Policymaker, a 10-minute guided policy generator for mobile apps. It provides robust first-party privacy policy for the app’s own data collection, but also automatically adds the right disclosure for ad-company tracking. This disclosure includes company-specific opt-outs when available, and can link to any Do Not Track approach that may emerge.

Over time, privacy choices will be embedded more elegantly into mobile apps and operating systems. But as a starting point, every app should have a privacy policy and apps with ads should include robust notice-and-choice for third-party tracking. Ad delivery companies are in the best position to make this happen directly with their publisher clients. If app developers can be asked to take this relatively painless step, choice may even come sooner—and be more meaningful—in mobile apps than it has been so far on the Internet.

About the Author

sp_brock_jim.jpgJim Brock

Jim Brock is Founder and CEO of PrivacyChoice. You can follow him on Twitter @privacychoice.

Continue the discussion on this IAB Ad Ops blog series on Twitter by adding #MeaningfulChoice to your tweets.



At Lotame, we’ve spent a lot of time and resources working to provide consumers with meaningful choice when it comes to their data usage in connection with Lotame’s services. And more generally, we have dedicated the lion’s share of our industry-wide collaboration over the past two years to this objective. So, as we motor along on the journey towards an even more data-driven digital future, we need to ask the age-old travel question in relation to our meaningful choice goal: Are we there yet?


In response, I would say “yes” and “not yet.” On the “yes” side, notwithstanding the often sensationalized press stories, steady barrage of advocate criticism, and periodic industry hand-wringing, there are now a plethora of privacy management tools available to consumers willing to invest in evaluating and acting on their choices. The industry has successfully rolled out a sophisticated enhanced notice platform, which is increasingly appearing on display ads around the Internet. This is no small feat given the industry-wide coordination and technical mechanics required to provide granular notice and choice options on a dynamic, standardized basis. In addition to this industry program, several other players in the marketplace offer consumer choice tools ranging from emerging Do-Not-Track options embedded within browsers to a gaggle of new consumer data management services. So if you (as a consumer) want to implement constraints around how your online data is collected, used, and shared, you have the tools available.

On the “not yet” side, we still have a way to go with the self-regulatory program. We need to effectuate much broader adoption and initiate real enforcement actions against companies who don’t comply. A recent study of top websites found that only 11% of ads served by third parties contained the enhanced notice “Ad Choices” icon. Even if industry players debate the methodology of the study, we’ve got to quickly increase that number to demonstrate that the self- regulatory program can be a comprehensive choice solution for consumers. We also need to keep extending the self-regulatory program to apply to all major ad types, including video, rich media, and mobile ads. Of equal importance to the self-regulatory program, we need our industry groups (not just outside “researchers” and advocates) to surface and curtail the atypical, on-the-edge practices that don’t align with industry standard—recent controversies over flash cookies, supercookies, and history-sniffing come to mind—so that consumers, advocates and regulators don’t feel like we are playing a privacy shell game.

Can we get there? I continue to believe we can, led by the new and growing breed of companies offering privacy management tools to both consumers and businesses. As part of getting there, all of us as consumers will also need to accept some responsibility for using the tools available to us and for acknowledging the trade-offs involved when our data is used to improve and subsidize the services from which we benefit. Is new legislation necessary? I don’t think so. I have serious concerns about the unintended consequences that will follow from any government effort to legislate choice mechanisms or further standards. New legislation will shackle a very dynamic and productive industry to backwards-looking technology and standards, putting the brakes on one of the few high-growth sectors in our economy. Imposing regulated restraints on data flow will also serve to artificially lock in an insurmountable lead for the biggest digital players who already sit on mountains of data (think search and social networking) which will ultimately be a disservice to consumers. What about reining in the “edge” practices that keep surfacing? As I said, we as an industry need to take the lead in ferreting these out. And regulators can already act on unfair or deceptive practices that don’t reflect broader industry standards. (I am intrigued by the recent comments from White House official Danny Weitzner about a new approach to implement “privacy law without regulation” which wouldn’t impose additional burdens on businesses with responsible privacy practices, but will need to see more details to understand whether this new approach changes my assessment above.)

Anyone who’s taken a long car trip with kids knows you don’t answer the “Are we there yet?” question just once. In this case, the same dynamic applies. We’ll need to keep asking and answering that question as it relates to meaningful choice and by doing so, we’ll continue to find ways to improve how we educate and empower consumers.

About the Author

sp_lehman_adam.jpgAdam Lehman

Adam Lehman serves as COO of Lotame Solutions. You can connect with him via Twitter @AdamL.

Continue the discussion on this IAB Ad Ops blog series on Twitter by adding #MeaningfulChoice to your tweets.



Insights from the IAB Ad Operations Community on Meaningful Choice

The consumer Internet is reshaping how businesses—not just consumer Internet or digital media businesses—understand and meet consumer expectations. Consumers expect control over their web experiences, as well as the data that sits behind the decisions companies make in shaping those experiences. They want to define the location and timing. When they show up, they would like to be recognized. Even harder, they expect their needs to be anticipated before they arrive. Finally, they expect hyper-efficient, machine-driven experiences that still feel human, personal, and catered to their needs.

In that spirit, our collective goal in digital media should be pretty simple: To make sure consumer web experiences are always meaningful, never creepy, and safer in the sense that they respect the end user’s wishes. Some consumers will opt-out of targeting entirely because they’re worried about privacy. But as a recent Krux poll clearly shows, 86% of US consumers want to actively control their online personas because they seek more meaningful, more relevant web experiences. Their principal concern is less about privacy, more about choice. For them a safer web experience isn’t about opting out; it’s about gaining control of their data signature. Many of us are investing time, capital, and sweat to make this happen, particularly on behalf of the publishers and marketers where most first-party consumer relationships reside.

Media begets data. Data begets more valuable media. They exist together in a virtuous circle that savvy operators use to deepen consumer relationships and improve business results.

Data is both media’s exhaust and its precondition: As users engage with media, they leave behind valuable data signatures via gestures, mouse-overs, clicks, conversions, and search, all of which hold the possibility of energizing more relevant, and thus more valuable, consumer experiences. Media is the mechanism by which a website transmits and creates value for its audience. Content (user-generated, curated, or publisher-produced), ad slots, commercial offers, communication services (text, social posts, or email) are the raw grist for the web operator’s revenue mill. Media begets data. Data begets more valuable media. You can no more weed out data from media, or media from data, than you can decouple heat from sunlight.

The opportunities to enrich advertising, content, and commerce experiences using consumer data are limitless. Amazon is a terrific example of a firm that seized on the potential early and practically wrote the book on how to manage consumer experiences to the benefit of both the user and the bottom line. The average user feels like Amazon knows them because it does. Amazon’s customers seldom worry about Amazon invading their privacy. To the contrary, they’re delighted by Amazon’s intelligent, personal touch. Soon, intelligent and personal connectivity will become part of everyday life (such as user-defined location aware alerts), and users will start to insist upon some measure of tracking and targeting so long as there is a fair exchange of value in doing so. As a result, I believe we’ll also see the often-frothy consumer privacy dialogue slowly shift to a more thoughtful discussion of what really matters: Consumer experience and consumer choice.

Despite how revolutionary the last decade of digital media may seem, we’ve really only scratched the surface. Our industry is the proving ground for technology and techniques that will soon power consumer interactions across enterprises, organizations, and institutions of every stripe and color. And while this digital future may be instantaneous and machine-driven, it will still be premised in human connections and a basic understanding of individuals’ needs and desires. It will be powered by intelligent, always-on services that continually make sense of the flood of data flowing across IP-enabled devices to inform decision-making and to anticipate and respond to peoples’ needs. At Krux, we see companies understanding and embracing this reality every day. Through the adoption of our Consumer Internet Data Management (CIDM) platform, many publishers and website operators are developing new ways to communicate and deepen relationships with the consumers they serve.

I worry, however, that if we don’t nail the choice questions early, we could see lots of smoke but no ignition from the Consumer Internet Data Management (CIDM) rocket as it sits on the launch pad. Our industry’s self-regulatory push—and delivering on meaningful choice—needs to go well beyond opt-outs and ad unit icons. It must be counterbalanced by choice and control, not as abstract policies or rules, but as infrastructure that give consumers enhanced web experiences and hews to their wishes one ad call, one cookie, and one page view at a time. Average consumers know very little—and care even less—about the vagaries of OBA, RTB, and DMPs. But those same consumers absolutely recognize a meaningful experience when it happens and can see plain as day whether or not their choices are being respected. Ultimately, delivering on meaningful choice is about leading with the value and clearly demonstrating to consumers the benefits they can reap from more relevant, personal web experiences. Only when that value proposition is cemented will the notion of choice become meaningful as we invite consumers to the table to have their say.

Since this blog series is intended to catalyze discussion, I’ll close with a few questions for the reader. Let’s take off our digital media hats for a moment and just be people. Far too often, the question is posed as how “we” can help consumers. Let’s dispose of that dividing wall. After all, we are the consumers we’re trying to help. Take a long look at what you did on the Internet today…reading the news, paying a bill, buying a sofa, whatever. Did you see your data signature at play in shaping your experience? Where did we get it right? How did we get it wrong? And when you put your digital media hat back on, what steps can we take to make experiences for all consumers, yourself included, cooler, safer, smarter?


Tom Chavez is the co-founder and CEO of Krux Digital. You can connect with him via Twitter @tommychavez.

Continue the discussion on this IAB Ad Ops blog series on Twitter by adding #MeaningfulChoice to your tweets.



Insights from the IAB Ad Operations Community on Meaningful Choice

multiplechoiceoryaltyfree.jpgAn amazing era in advertising is emerging when we can finally deliver a much-heralded but yet-to-be-realized promise: the right ad in the right place at the right time. We worry about how Do Not Track, Opt-Out, the FTC, and privacy enthusiasts will negatively impact our business models. But while we fret, we often fail to recognize new innovations making consumers’ lives better each and every day.

Yes, consumers need the ability to opt out. However, they also want options to improve their online experience. They may want help shopping for shoes. But they may not want to see the same Zappos ad after they just bought a new pair.

We call this Meaningful Choice. Through this blog series, we’ll explore perspectives on this exciting new concept with the IAB ad operations community. Our focus will be on two questions. What does Meaningful Choice mean to you? And how do we, as an industry, deliver Meaningful Choice into the hands of consumers?

As the blog series moderator, I want to avoid unduly influencing future contributions by describing what I think meaningful choice is. But, I am willing to say what it is not.

When provided with a choice of mostly incomprehensible options, a person is going to choose the one thing they understand. Take this overly dramatic metaphor for example: Your naturopathic physician friend offers you a bag of pills of different sizes, shapes, and colors but with no discernable markings. She tells you, “You can live without these—most of them are harmless and some of them are extremely beneficial, but one is deadly. Choose any combination of them that you would like, or, of course, you can opt out altogether and take none of them.” The only real choice in this scenario is to opt out completely. You would not have a Meaningful Choice.

When the average consumer sees an industry opt-out page, she is presented with a similarly well-intentioned yet meaningless set of options. We give her a list of companies of which she has no knowledge, no understanding, and no reason to trust. Often, the only choice is to opt out of all of them.

One may argue that the average consumer is smarter than that, but if I had a dollar for each time an industry insider shared with me a story of buying something only to be aggressively targeted with ads for that same product over the following months, I would have at least $20.

“I don’t want to have to opt out, I just want to tell somebody that I already bought those shoes.”

This lack of choice is not just affecting display advertising:

“Whilst I’ve always thought of interest targeted ads as a good thing (who wants to be presented with something completely different to what you like?) they are starting to get on my nerves a fair bit. Every day I’ll go onto the web and see the same old adverts, day after day. I’ve already signed up for these products…why are they still trying to get me again? So yeah…I’ll be turning this off.”


Online behavioral advertising self-regulation is a huge step in the right direction. It has been slow, but that is, in part, because we are still thinking about it as self-regulation. The infrastructure behind the Online Behavioral Advertising (OBA) program is exactly the vehicle we need to open a meaningful dialogue with the consumer. Instead of, “How do we meet the minimum bar for self-regulation?” we should be asking, “What should our dialogue be with the consumer?” After all, that dialogue is the future of advertising.

Steve Sullivan is VP of Digital Supply Chain Solutions for the IAB. You can follow him on Twitter @stevesullivan32. Continue the discussion on “Meaningful Choice”, and this IAB Ad Ops blog series, on Twitter by adding #MeaningfulChoice to your tweets.