Apidays New York 2024 - Scaling API-first by Ian Reasor and Radu Cotescu, Adobe
Damian Scragg, Evidon - Making Privacy Sexy
1. See, understand and
control data online.
Confidential | DraftDraft for Discussion Purposes Only
Confidential | for Discussion Purposes Only
20122012 Evidon, All Rights Reserved.
Evidon, Inc. Inc. All Rights Reserved.
2. Evidon empowers
consumers and businesses
to see, understand and
control data online.
Confidential | Draft for Discussion Purposes Only
2012 Evidon, Inc. All Rights Reserved.
3. Making privacy sexy…
Confidential | Draft for Discussion Purposes Only
2012 Evidon, Inc. All Rights Reserved.
4. Protect consumers’ privacy
consumers
Confidential | Draft for Discussion Purposes Only
2012 Evidon, Inc. All Rights Reserved.
5. • 6+ million downloads
• 1.6+ million active weekly panel members
• Only comprehensive tracking code library
Confidential | Draft for Discussion Purposes Only
2012 Evidon, Inc. All Rights Reserved.
6. Protect consumers’ privacy
Confidential | Draft for Discussion Purposes Only
2012 Evidon, Inc. All Rights Reserved.
7. Protect your business
businesses
Confidential | Draft for Discussion Purposes Only
2012 Evidon, Inc. All Rights Reserved.
8. Protect your business
Know your site
• Who are they?
What do they do?
• How often do they appear?
• How do they affect my
site performance?
• Does their opt-out work?
• Is my site “cleaner” than
my peers?
Confidential | Draft for Discussion Purposes Only
2012 Evidon, Inc. All Rights Reserved.
9. Protect your business
Everywhere
AdChoices
Confidential | Draft for Discussion Purposes Only
2012 Evidon, Inc. All Rights Reserved.
11. EU ePrivacy Directive
A LAW requiring:
• Notice when collecting/using a
European consumers’data
• The means to control how
their data is used
• For all forms of tracking, not just
cookies and/or online behavioural
advertising (OBA)
• Consent
Confidential | Draft for Discussion Purposes Only
2012 Evidon, Inc. All Rights Reserved. 11
12. Where The Law Stands
• EU law ratified Iceland
Sweden Finland
• Each member state
required to pass Norway
Estonia
similar law Denmark
Latvia
Lithuania
United
Ireland Kingdom
• May 25 UK deadline! Nether
lands Poland
Belgium
Germany
Czech
Lux. Republic Slovakia
Moldova
Austria
Law passed (blue) France
Switzer
land
Slovenia
Hungary
Croatia
Romania
Bosnia Serbia
Bulgaria
Italy Montenegro
Macedonia
Portugal
Albania
Spain
Greece
Cyprus
Law proposed (yellow)
Confidential | Draft for Discussion Purposes Only
2012 Evidon, Inc. All Rights Reserved. 12
13. Consumer CONSENT Required
But may be interpreted differently per territory
Implied Explicit
Could be satisfied by user simply Could include proactive browser setting,
leaving default privacy settings as collection of opt-in cookie before data
they are. collection/use, etc.
Currently: Currently:
• Bulgaria • Italy • Cyprus
• Czech Republic • Luxembourg • France*
• Denmark • Malta • Greece
• Estonia • Slovakia • Latvia
• Finland • Slovenia • The Netherlands*
• Germany* • Spain* • Poland
• Hungary • Sweden • Portugal
• Ireland • United Kingdom* • Romania
• Lithuania
Currently unclear: Austria, Belgium, Iceland, Liechtenstein, Norway
Source: Field Fisher Waterhouse Cookie Consent Tracking Table, February 2012,
http://www.ffw.com/pdf/cookie-consent-tracking-table.pdf, Evidon analysis.
* Discussions between industry and regulators still ongoing
Confidential | Draft for Discussion Purposes Only
2012 Evidon, Inc. All Rights Reserved. 13
14. May 25th is the
beginning and not the END!
…..so what does it mean for all of you?
Confidential | Draft for Discussion Purposes Only
2012 Evidon, Inc. All Rights Reserved.
15. Site owners:
the law applies to you
…storing of information, or the
gaining of access to information
already stored, in the terminal equipment of a subscriber or user
is only allowed on condition that
As long as data is
the subscriber or user concerned
collected, used,
has given his or her consent, having same compliance
been provided with clear and comprehensive information, in
accordance with Directive 95/46/EC.... obligation
DIRECTIVE 2009/136/EC OF THE
EUROPEAN PARLIAMENT AND OF THE COUNCIL
of 25 November 2009
Confidential | Draft for Discussion Purposes Only
2012 Evidon, Inc. All Rights Reserved. 15
16. Take action now!
1. Audit and continually monitor tracking across sites
2. Review your privacy policy & consider a cookie policy
3. Deploy consent solutions
Confidential | Draft for Discussion Purposes Only
2012 Evidon, Inc. All Rights Reserved. 16
17. The Audit
• First step requested by ICO and CNIL
• The Audit is the responsibility of the site owner
• Not just cookies – all forms of tracking!
• Should not be a one off process
• Continual monitoring should be best practice
Confidential | Draft for Discussion Purposes Only
2012 Evidon, Inc. All Rights Reserved. 17
18. Drops 8 cookies
Has no opt-out
Takes 86ms to load
Uses flash cookies
Confidential | Draft for Discussion Purposes Only
2012 Evidon, Inc. All Rights Reserved.
19. Gaining Consent
• Empower consumers; get their
consent to be tracked
• 1st & 3rd party tracking
• Only a limited field of strictly necessary cookies/tracking
• Comply with privacy regulations
• Grow your business
Confidential | Draft for Discussion Purposes Only
2012 Evidon, Inc. All Rights Reserved. 19
20. Protect your business
Disclose + get consent
Confidential | Draft for Discussion Purposes Only
2012 Evidon, Inc. All Rights Reserved.
21. Garden and Grow
http:/ / www.gardenandgrow.com Google
Cookie Consent
About Cookies on this site: Remove message
Our site uses cookies and other technologies so that we and our partners can remember you,
make the content you see more relevant and generally improve your browsing experience. Read
more about cookies here. Through our Cookie Consent Wizard, available on every page on our
site, you can see a complete list of these cookies and technologies and set your preferences.
Confidential | Draft for Discussion Purposes Only
2012 Evidon, Inc. All Rights Reserved. 21
22. Confidential | Draft for Discussion Purposes Only
2012 Evidon, Inc. All Rights Reserved. 22
23. Explicit Consent Option
Garden and Grow
http:/ / www.gardenandgrow.com Google
We need your consent to proceed!
Our site uses cookies and other technologies so that we and our partners can remember
you, make the content you see more relevant and generally improve your browsing
experience.
To see a complete list of these cookies and
technologies and to set your cookie preferences, Cookie Consent Wizard
access our Cookie Consent Wizard:
When you proceed to access our site, we will use
such cookies and technologies as presented in the
Cookie Consent Wizard. Your consent, which you Agree and Access Site
can withdraw at any time, will be set with a cookie
from our privacy partner, Evidon.
For more details about how information is accessed and stored on this site see our
Privacy Policy.
Privacy Controls by Evidon Why am I seeing this notice?
Confidential | Draft for Discussion Purposes Only
2012 Evidon, Inc. All Rights Reserved. 23
24. Confirmation Message
Garden and Grow
http:/ / www.gardenandgrow.com Google
We need your consent to proceed!
Our site uses cookies and other technologies so that we and our partners can remember
you, make the content you see more relevant and generally improve your browsing
experience.
To see a complete list of these cookies and
technologies and to set your cookie preferences, Cookie Consent Wizard
Thank you for providing your consent!
access our Cookie Consent Wizard:
Remember that you can withdraw your consent at any time with
When you proceed toConsent Wizard, will use
our Cookie access our site, we available on
every page.
such cookies and technologies as presented in the
Cookie Consent Wizard. Your consent, which youAgree and Access Site
can withdraw at any time, will be set with a cookie
Cookie Consent Wizard
from our privacy partner, Evidon.
For more details about how information is accessed and stored on this site see our
Privacy Policy.
Privacy Controls by Evidon Why am I seeing this notice?
Confidential | Draft for Discussion Purposes Only
2012 Evidon, Inc. All Rights Reserved. 24
25. Evidon + TagMan
= simple workflow and tag control for site
“Data Aggregator
has collected info
about you!”
1 Person clicks on
a car ad and
lands on a
3 Tag Manager tells
Evidon about that tag…
car website. …so Evidon can notify
the person that the Data
Aggregator has collected
info about them.
2 4
Tag Manager loads If the person takes some
a relevant tracker tag action, e.g., opts out,
(e.g., a Data Aggregator, Evidon tells Tag Manager
which adds this person so, the next time it sees
to its “auto intender” that user, it doesn't’t load
segment). that Data Aggregator.
• Simplicity: site notice auto-populates
• Consumer preference more assured—
their choices communicated to both
tracker and site/tag manager
Confidential | Draft for Discussion Purposes Only
2012 Evidon, Inc. All Rights Reserved.
26. Site Owner Obligations – managing
stakeholders
• Site Owners control only some of the tracking that appears on their
websites
• Ensure that your tech, agency and network partners are disclosing
all of the tracking that they are carrying out
• Request that companies serving ads directly to your site – networks,
tech providers are displaying the AdChoices icon within their ads
• Where you are trafficking your own campaigns – be sure to traffic
the AdChoices icon
• Ensure your AdChoices disclosure gives “clear and comprehensive
information” and that you have a consent mechanism in place
Confidential | Draft for Discussion Purposes Only
2012 Evidon, Inc. All Rights Reserved. 26
27. In Summary
1. Audit and continually monitor tracking across sites
2. Review your privacy policy & consider a cookie policy
3. Deploy consent solutions
Confidential | Draft for Discussion Purposes Only
2012 Evidon, Inc. All Rights Reserved. 27
28. Thank You.
Damian Scragg
Managing Director, UK
dscragg@evidon.com
Confidential | Draft for Discussion Purposes Only
2012 Evidon, Inc. All Rights Reserved.