Agenda21 eu cookie seminar - dominic trigg - rocket fuel
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Agenda21 eu cookie seminar - dominic trigg - rocket fuel
- 1. Rocket Science for Digital Advertising Our concern for Privacy Dominic Trigg
- 2. Outline Building on the Information of my distinguished colleagues Rocket Fuel and why privacy is important Privacy Landscape of Behavioral Networks – Rocket Fuel’s Perspective UK Cookie Law International Privacy Insights Our Approach to this
- 3. Rocket Fuel, Inc. Rocket Science for digital advertising Technology company driving outstanding results for digital marketers » Founded: 2008 » People: 167 » Offices: 11 » Data centers: 5 (US, Europe, Asia) » Customers: 709 » Campaigns: 1,849 » Revenues: $44.5M in 2011 » Growth: > 2.7x revenue growth every year
- 4. Exchanges now allow reach of billions of consumers So Privacy has become a worldwide issue for us 83% 54% 97% 64% 33% 92%
- 5. We buy audience via a huge numbers of networks and sites So Privacy concern translates into a Europe wide issue for us Global Exchange Partner Sample Ad Exchange
- 6. Data providers come in all shapes and sizes in Europe Using Data Providers that are trustworthy is absolute necessity Market Example Data Provider United Kingdom Germany The Netherlands France
- 7. Privacy Landscape of Behavioural Networks Rocket Fuel’s Perspective
- 8. Clearly, Privacy Now Has Attention Spectacular Missteps have raised sensitivity
- 9. Behavioural Networks are right in the middle of it Therefore, we believe Consumers want better targeted advertising Data is necessary to better target ads Better targeted ads improve conversion and benefit businesses Increased message relevancy, driven by advanced data usage and capture, improves the overall consumer experience. Consumer privacy is important and has to be respected but content needs to be paid for. Transparency is essential
- 10. Privacy Principles Building blocks to identify actionable strategies Consumer Education Transparency Control Material Data Security Sensitive Data Changes Accountability
- 11. Offering Consumers a Choice Education Educate consumers and businesses about OBA and Privacy Explain user data collection and describe how consumer choice and control may be exercised Offer consumers a simple way to control what information is shared
- 12. Informing Consumers about what happens and give them control Transparency and Consumer Control Enhanced notice link Companies should give clear, meaningful and prominent notice on their data collection, sharing, and use practices First and third party responsibilities Consumers choice whether their data is collected, used and transferred Ability given to users on website or within ad unit
- 13. Most importantly are Trust in proper Stewardship of Data Data Security Implement reasonable safeguards to protect data that is collected Retain data only as long as necessary to fulfill a legitimate business need “Anonymise” any personally identifiable information Rocket Fuel’s data retention policy keeps consumer data for 30 months
- 14. Other Important but less defined Principles Material Changes, Sensitive Data and Accountability Material Changes Opt-In for Sensitive Data • Children, especially young children • Recognize that privacy concerns are real and create new responsibilities for • Collection of financial account every digital player’s handling of data information, prescriptions, or medical records Accountability • Develop and implement policies and programs to adhere to the principles • Involves systematic or random monitoring of programs for compliance
- 15. UK Cookie Law
- 16. Protecting Consumer Rights - UK
- 18. Cookie Directive Breaking down the UK Cookie Law »Deadline: May 2012 »Disclose collection and use of data »Opt out option for behavioral advertising. »ICO made suggestions for third party cookie providers
- 19. Make efforts to take Confusion Out Of Cookie Directive What is Rocket Fuel doing? » We now serve every behaviorally targeted ad with the Ad Choices icon
- 21. A European DAA • The “Your Choices” Program • Provides transparency about OBA data collection and usage across the EU organized by the IAB UK. • It is based on a framework published by European Advertising Standard Associations (EASE) and supported by the European IAB. • Implemented in 22 European countries, including Western Europe & The Baltics • Rocket Fuel is a registered member of the Your Choices program and is compliant with data transparency and collection rules
- 22. European Union Privacy Directive Background European Union E-Privacy Directive 2002/58/EC • Passed July 2002, amended December 2009 • Requires user consent to be obtained for information stored or accessed on user’s terminal equipment • Prior to obtaining consent, users must be provided with clear information about the purpose of the storage or access • Member states initially given implementation deadline of May 2011 • European Commission recently updated implementation deadline to June 2012 EU Privacy Directive Requirements • Requires user consent, suggests users must Opt In to cookie storage • Applies directly to first parties (publishers), suggests some responsibility for third parties •Doesn’t apply to “strictly necessary'” cookies ( Ecommerce , enhanced experience)
- 23. EU Member States That Have Acted Member Legislative Details Opt In / Implementation Enforcement State Status Opt Out Options UK Cookie Law passed 1st/3rd party cookie Opt In • Site Notification Enforcement 5/25/2011, parties provider must prove • Site Header/Pop- Begins 5/26/2012 have 1 year to user consent Up comply Germany Legislation drafted Explicit consent Opt In • Site Notification Unknown but is farthest from required, • Site Header/Pop- implementation implementation Up requirements being debated Netherlands Upper house of 1st/3rd party cookie Opt In • Site Notification 7/1/2012 if Dutch Senate yet to provider must prove • Site Header/Pop- ratified ratify user consent Up Denmark Awaiting Consent via browser Opt In • No Action Taken Unknown implementation of settings draft bills Finland Finnish parliament Consent via browser Opt In • No Action Taken N/A implemented in settings 2011
- 25. Conservative and Responsible on Behalf of Our Advertisers Rocket Fuel applies the following to every campaign We are careful and conscious of how we transfer data across borders We ensure that direct publishers and exchanges we obtain inventory from are 100% compliant We provide all users with a second opportunity to opt out when third party cookies are being served We work with the third party OBA vendor Evidon to ensure OBA icon is serving correctly, in line with all regulations We maintain the ability to work with any third party ePrivacy vendor that any client requires
- 26. Interpretations of Business Consequences Rocket Fuel’s estimate of impact based on strategy chosen The E-Privacy Directive is ambiguous on how and when user consent is to be collected. Possible interpretations include: Option Opt In/Opt Out? Technology Cookie Loss No Action Taken Opt Out Web Browser 0% Ad/Your Choices Opt Out NAI/DAA/Evidon/Ro 2% Notification cket Fuel Website Opt Out Site Message 10% Notification Site Header/Pop- Opt In Accordion 50% Up Header/Pop-Up
Editor's Notes
- Origin of Numbers: HR Department Headcount (monthly update by office), Customers and Campaigns since beginning of January 2010 according to the business operations department
- Far too many companies that collect and use consumers' personal information have not dealt in a fair and above board fashion with consumers about the types of personal information they are collecting, how they are using that data, and who they are sharing that data with;Most consumers are powerless to control, in any meaningful way, how and to which parties their personal information and data should flow; andThere were far too many instances in which the flow of that data defied consumers' reasonable expectations about how that data might be used and shared.Lack of transparency.All of this has snow balled.
- 30 days or Months?
- FTC has been the nation’s chief privacy policy and enforcement agency for the past 40 yearsDepartment of Commerce has also been involved in setting policyCongress has the real authority to make changesFTC involved since 1995, actually 1970s.Stave off regulation in a fast moving space. Hasn’t proven to be effective.Now house & senate also getting involved
- The Cookie Law was enacted in the UK in May of 2011, based on the European Union Data Protection Directive. The UK Law applies to how websites use cookies to store information on an individual’s computer or mobile device. Websites will now feature helpful information about the collection and use of data, as well as information about how an individual can decline behavioral advertising.The ICO suggests that third party cookie providers such as Rocket Fuel and the advertisers we work with, should partner with first party providers to offer users information and choice regarding the way their personal information is collected.
- Rocket Fuel partners with direct publishers and exchanges that are compliant with the law Every behaviorally targeted ad Rocket Fuel serves includes the OBA Ad Choices icon. This icon provides individuals with an additional opportunity to opt out of cookie collectionRocket Fuel works with third party compliance companies such as Evidon, TRUSTe and DoubleVerify to ensure that the Ad Choices icon is served correctly, with every ad, and in line with all regulationsRocket Fuel supports the industry’s self regulatory “Your Online Choices Program”, which provides a central location for individuals to learn more about online behavioural advertising and online privacy.
- DAA? OBA?