Steve Sullivan: January 2012 Archives
Earlier this summer, the Digital Advertising Alliance (DAA) confirmed the names of the first 100 companies participating in the Self-Regulatory Program for Online Behavioral Advertising (OBA). These cross-industry companies reflect the biggest brands, publishers, and ad networks in our ecosystem. Last November, the DAA significantly expanded the scope of the self-regulation program beyond online behavioral advertising (OBA) to establish a clear framework to govern the collection and usage of data which includes a consumer choice mechanism for managing data collection practices.
All of these self-regulatory actions—implemented widely across the industry—are further proof that we continue to respond responsibly to privacy concerns with incremental and critical enhancements that improve consumer protection, choice, and control in online advertising.
Yet, there remain gaps in adoption and implementation, mostly due to lingering confusion about when the advertising option icon should be included on an ad and the responsibility of each party involved in the buying, selling, and delivery of that ad.
One of the OBA principles state that enhanced notice (via the icon that is often accompanied by the language Interest-Based Ads or AdChoices) must be served on or close to the ad when the ad is either behaviorally targeted or if data is being collected that could be used for future behavioral targeting. The responsibility to uphold this principle applies to every one of the parties involved in delivery of that ad: the advertiser, the agency ad server, the publisher ad server, and any ad network, exchange, DSP, or SSP. It is safe to assume that every single one of these parties involved in delivering a campaign captures a cookie, an IP address, and a variety of other data points that could be used for future behavioral targeting. As such, it’s imperative that any likelihood of data being collected and used, whether before or after an ad is delivered, is clearly communicated to the consumer.
So let’s be CLEAR*: We should expect to see an advertising option icon on almost every ad, even if that ad is not behaviorally targeted.
What about instances where there is absolutely no data being used or collected? Allowing for some notable exceptions (discussed in more detail below) shouldn’t that be communicated to the consumer as well?
Consider the USDA’s food label for a moment: As a consumer concerned about my health, I review labels to determine how many calories I am consuming. If you look at the USDA label on some diet soft drinks, you will see nothing but zeros because they have 0 sugar, 0 sodium, 0 fat, and therefore, 0 calories. So, why do they put the label on the can if there is nothing to report? The reason is that the presence of a “0” on the label provides useful information for the consumer. The absence of the label represents, well, zero information. In fact, I would be very suspicious of any beverage that had no USDA label. It’s this very suspicion that is pervasive among consumers in regards to online advertising.
For this same reason, it’s not enough to include the advertising option icon only when targeting is being used or cookies are being dropped. The ubiquitous presence of the advertising option icon will reassure consumers that, with one click, they can find the information they need about that ad and the industry players who served it, even if the message is, “This ad was not targeted.”
As Evidon has pointed out to the industry, it should be just as simple as reading the USDA Nutritional label: Click on the advertising option icon and instantly know:
- Who served the ad
- If the ad was served using behavioral targeting
- If the ad is collecting data for future usage
- Where to go for more information about the industry
There will be some exceptions to this general rule, most notably, pharmaceutical ads and certain rich media and video formats, where the industry is still navigating implementation challenges. It is also true that the OBA principles don’t specifically mandate the omnipresence of the advertising option icon, but if we can make it easier and clearer for the consumer to understand the choices they have and make a decision, we all win: consumer, publisher, and advertiser.
In order to reach that winner’s circle, we all have to pitch in, not just the final party who serves the ad. Advertisers need to plan for the advertising option icon and think about how its presence (and placement!) will impact their overall creative and media plan strategy, as well as their own websites. Publishers and ad networks need to continue to be transparent with and respectful of consumer data. And we all must accept the ubiquitous-ness of the icon on every ad.
Stay tuned for a follow-up post in which we’ll highlight some tactical plans for delivering an easier and clearer choice—and decision—mechanism for consumers.
* CLEAR = Control Links for Education and Advertising Responsibly
About the Author
Steve Sullivan is VP of Advertising Technology at the IAB. You can follow him on Twitter @stevesullivan32.