Transcript Online Behavioral Advertising (OBA)

C&SR Update
Senny Boone
Senior VP, Corporate & Social
Responsibility
Online Behavioral Advertising
Global Symposium Update
DMA Self-Regulation
Corporate & Social Responsibility
Commitment to Consumer Choice
(CCC)
Members commit to protecting individual
privacy and offer choices to consumers
by addressing consumer preferences in
ways that secure continued selfregulation and growth of direct marketing
across channels.
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Online Behavioral
Advertising (OBA)
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Online Behavioral Advertising (OBA)
What Is It?
“Online Behavioral Advertising” means
the collection of information from a
particular computer or device regarding
Web viewing behaviors over time and
across non-Affiliate Web sites for the
purpose of using such information to
predict user preferences or interests to
deliver advertising to that computer or
device based on the preferences or
interests inferred from such Web
viewing behaviors.
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ISPS
AGENCIES
ADVERTISERS
PUBLISHERS &
PORTALS
BROWSERS
Effective Compliance
AD NETWORKS,
EXCHANGES & DATA
TRADE ASSOCIATIONS
GOVERNMENT
AD SERVERS
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Online Behavioral Advertising
Who Is Impacted?
 Third parties: An entity that engages in
OBA on a non-affiliate’s website must
comply with OBA provisions
 “First” parties: The owner of the
website that has control over the
website and its affiliates. Both website
owners and affiliates need to review
their online privacy policy for OBA
notice and consent issues & review
their “material changes” process
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Online Behavioral Advertising
Advertising Notice & Choice
 If you collect personally identifiable info (PII)
online
OR
 If you collect info from non-Affiliate websites
for OBA purposes:
Need NOTICE
Includes type of information collected, types
of uses, any transfers of information, use of
cookies, security measures, transfers to
third parties.
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Online Behavioral Advertising
Advertising Notice & Choice
OPTION #1
If you operate a website that may have OBA
conducted by Third Parties
 ADD A LINK WHERE THE INFORMATION IS
COLLECTED OR USED that links – EITHER
-To DMA-approved websites (such as
DMAchoice.org) that lists OBA third parties
OR
-To a link that individually lists the OBA third parties
 BOTH need to have a way for a consumer to
exercise preferences (CCC)
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Online Behavioral Advertising
Advertising Notice & Choice
OPTION #2
If you operate a website that may have OBA
conducted by Third Parties
 ADD A LINK WHERE THE INFORMATION IS
COLLECTED OR USED
 UNLESS the Third Party provides Enhanced Notice
of OBA
 Also, if your policy changes and you plan to SHARE
information for OBA purposes, you must:
- Update your policy
- Give consumers conspicuous notice of the change
-
and offer preferences
Provide them an opportunity to select their preferences
If you use info collected for OBA purposes before a
notice is provided, you must get informed consent
from the consumer
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Online Behavioral Advertising
Enhanced Notice
Third Parties should provide
Enhanced Notice (easy to find,
understand, read, act on)
 Industry-developed website
 Prominent link described in or around the
advertisement
 On the Web page where the info is collected, or
where info is collected for OBA
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Online Behavioral Advertising
Example of Enhanced Notice
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Online Behavioral Advertising
Example of Website Notice
Notice by Website
Third parties who place advertisements on our
websites may collect and use information about your
visits to our websites and other websites in order to
provide advertisements about goods and services of
interest to you. If you would like to obtain more
information about the practices of some of these
third parties and to make choices about their use of
your information, please click here.
preference Ads
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Online Behavioral Advertising
OBA Service Providers
Those who collect and use information
from URLs traversed by Web browsers
across websites for OBA purposes as a
provider of Internet access service, a
toolbar, an Internet browser, or other
applications.
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Online Behavioral Advertising
OBA Service Providers
OBA Service Providers must get a
consumer’s consent before engaging in
OBA and should include an easy method
for the consumer to exercise their
preferences/withdraw their consent to
such activities
 ISSUE -Examine how to operationalize this, since a
service provider needs to integrate the OBA
consent with an individual’s records/URLs
 For the information collected:
-Alter, anonymize, randomize & disclose this in the
notice
-Protect if sent to others to avoid reconstruction of
information
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Online Behavioral Advertising
OBA Definitions & Terms
Via Glossary
-Affiliate
-Control
-First Party/Third Party
-Ad Delivery
-Ad Reporting
-Consent
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Online Behavioral Advertising
OBA Definitions & Terms
 Affiliate is the entity that controls or is controlled
by or is under common control of an entity
 Control means the entity is under significant
common ownership or operational control, or
has a controlling influence
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Online Behavioral Advertising
OBA Definitions & Terms
 Ad Delivery: delivery of online ads or ad-
related services using ad reporting data, but
not collection & use of such data which is OBA
 Ad Reporting: logging of page views on a
website, info about browser, operating system,
domain name, date & time of the Web page
viewing or other stats, analysis of website ads
served
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Online Behavioral Advertising
OBA Definitions & Terms
Consent: An individual’s action in response to a
clear, meaningful prominent notice regarding
OBA.
IF IN DOUBT—PROVIDE THE NOTICES & CHOICE
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Online Behavioral Advertising
Other Online Guidelines Reminders
 Material Change to existing policies & process
 Third-Party Use consent by consumer
 Marketing Data used only for marketing purposes
(Article #31)
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Online Behavioral Advertising
Other Online Guidelines Reminders
Information Security
 Organizations should retain information used for
OBA purposes only as long as necessary for a
legitimate business need or as legally required
Protecting Children:
 Organizations should not engage in OBA purposes
directed to children under age 13 and must review
the COPPA (Children’s Online Privacy Protection
Act) for compliance
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