Transcript VeriSign Interactive Application Services

Privacy & Preference Committee Update
Ensuring a healthy ecosystem via transparency & trust
Date: January 13, 2009
Alan Chapell, President
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The Privacy Professional’s Message
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Why is this year different?
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Why else is this year different?
Mobile is Big…
… and getting Bigger
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“Chapell’s” Law
As $$$$ increase
… scrutiny also increases
Privacy & Preference Committee Membership
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MMA Privacy Committee
2008 Goal: Globalize the Code of Conduct
2009 Goal – Implementation Guide
How do we apply the Code of Conduct in real
world situations?
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Case Studies
(how privacy, IP & revenue intersect)
Brand Advertiser Case Study
The mobile team for a large consumer brand is putting
together an SMS program. They’ve collected 1MM mobile #s
in compliance with law and MMA standards. They are about
to deploy their first wave of messages when the brand
manager gets a call from legal with two questions
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Did you scrub the list of mobile #’s against the DNC list?
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Are there any children under 13 on the list?
Legal won’t let the campaign commence until these questions
are addressed… what now?
Mobile Cookies
A mobile advertising network announces that they’ve
developed a ‘cookie’ mechanism and are about to implement it
across their network.
A reporter from the trade press calls the company and asks:
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Are these cookies tied to wireless #’s or other PII?
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How does the user opt-out from these cookies?
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Are the cookies stored on the device or on the server?
No sympathy just because the cookie isn’t implemented yet
Mobile Gaming
There’s a new mobile game that all the cool kids are playing –
it combines ‘Risk’ with ‘Second Life’. The game knows the
location of all players and serves targeted advertising via SMS
based on location.
You want your brand to advertise via this game. What should
you consider?
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Is the game targeted at children? (Cartoon Characters)
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Does the game contain UGC?
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How precisely does the game pinpoint location, and does the
user understand that his location is available for ads?
Social Networking
A consumer sends an SMS message (opting in) to a social
networking platform to receive SMS messages about their
favorite band. Who ultimately ‘owns’ the customer? Who owns
the Data?
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The Band?
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The carrier?
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The SN technology service provider?
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The band’s Record label?
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The User?
Data Collection
A large media company is collecting names for a sweepstakes
via SMS campaign. Most registrations are obtained via a web
based landing page. Users provide their name, cell # and date
of birth, and are immediately sent an SMS message confirming
their entry into the sweepstakes.
Someone enters their date of birth as May 4, 1997 and are
sent the SMS message.
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Did the media company violate the Children’s Online Privacy
Protection Act?
Mobile Application
A mobile technology company has partnered with a media
company to offer a downloadable application that serves ads
via SMS and other mechanisms within the phone. The
application collects the User’s name, phone, email and a good
deal of non-PII about the User. Some of that User information
is shared with the carrier, the media company and various
other technology intermediaries.
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Who ‘owns’ the data collected via the application?
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Who’s terms and conditions and privacy policy governs?
Carrier as Data Engine?
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Clear messaging
is more important
than ever
Esp given mobile’s
Limited Real Estate
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Thanks!
MMA Privacy & Preference Committee
Alan Chapell
President
Chapell & Associates
917-318-8440
[email protected]
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