The IAB’s Targeting/Data Collection Glossary: Oh, What a Tangled Privacy Threatened Web They Weave [Annals of Geo. Orwell meets Madison Ave.]

The Interactive Advertising Bureau has released for public comment a telling document that illustrates why Congress and the FTC need to develop some rules to protect consumers.  Take a look at the definitions the IAB has embraced on targeting and data collection–and ask yourself.  Based on what they say, can this really be–as the IAB claims–non personal information? Here are some of the definitions from the Networks & Exchanges Quality Assurance Guidelines [Feb. 2010]:

*Audience Targeting:A method that enables advertisers to show an ad specifically to visitors based on their shared behavioral, demographic, geographic and/or technographic attributes.  Audience targeting uses anonymous, non-PII data.

*Behavioral Targeting:  Using previous online user activity (e.g., pages visited, content viewed, searches, clicks and purchases) to generate a segment which is used to match advertising creative to users (sometimes also called Behavioral Profiling, Interest-based Advertising, or online behavioral advertising).  Behavioral targeting uses anonymous, non-PII data.

*Attribute – A single piece of information known about a user and stored in a behavioral profile which may be used to match ad content to users.  Attributes consist of demographic information (e.g., age, gender, geographical location), segment or cluster information (e.g., auto enthusiast), and retargeting information (e.g., visited Site X two days ago).  Segment or cluster information is derived from the user’s prior online activities (e.g., pages visited, content viewed, searches made and clicking and purchasing behaviors).  Generally, this is anonymous data (non-PII).

*Behavioral Event – A user-initiated action which may include, but not limited to: searches, content views, clicks, purchases, form-based information and other interactions.  Behavioral events are anonymous and do not include personally identifiable information (PII).

*Clickstream Data – A Clickstream is the recording of what a computer user clicks on while web browsing.  As the user clicks anywhere in the webpage or application, the action is logged on a client or inside the web server, as well as possibly the web browser and ad servers.  Clickstream data analysis can be used to create a user
profile that aids in understanding the types of people that visit a company’s website, or predict whether a customer is likely to purchase from an e-commerce website.

*Cookie – A small text file sent by a website’s server to be stored on the user’s web- enabled device that is returned unchanged by the user’s device to the server on subsequent interactions.  The cookie enables the website domain to associate data with that device and distinguish requests from different devices.  Cookies often store behavioral information.

*Cross-site Advertiser Analytics – Software or services that allow an advertiser to optimize and audit the delivery of creative content on pre-bought publisher inventory.  Data can range from numbers of pages visited, to content visited, to purchases made by a particular user.  Such data is used to surmise future habits of user or best placement for a particular advertiser based on success.


*Deep Packet Inspection – A form of computer network packet filtering that examines the data and/or header part of a packet as it passes an inspection point. In the context of online advertising, it is used to collect data, typically through an Internet Service Provider, which can be used to display targeted advertising to users based on previous web activity.

* Retargeting (or re-targeting) – The use of a pixel tag or other code to enable a third-party to recognize particular users outside of the domain from which the activity
was collected. See Creative Retargeting, Site Retargeting.

*Creative Retargeting:  A method that enables advertisers to show an ad specifically to visitors that previously were exposed to or interacted with the advertisers’ creative.

*Unique User – An individual user that has interacted with online content, which is smaller than or equal to the number of cookies observed.  The number of unique users to a website is usually an estimate.  

Yahoo to Pharma Marketers: Come `Engage’ & Target Health Consumers Online


As my CDD has explained to both the FDA and FTC, the digital marketing of drugs and health information require serious privacy and consumer protection safeguards.  What may be acceptable when selling cars & travel online using the online ad tool-set is not appropriate when transferred wholesale to such sensitive categories as drugs.  Here’s an excerpt [pdf] from Yahoo!s promotional piece entitled “Social Media:  Pharmaceutical Marketing in the Age of Engagement.”

Social media marketing is a compelling opportunity for pharmaceutical companies to reach their most influential audience. Recent research conducted by Manhattan-based Hall and Partners Healthcare found that online health consumers are hyper-engaged and leverage almost twice as many information sources

to learn about disease states and prescriptions than the average consumer… For every creator of content – a physician writing a blog, for example – there are

roughly 10 synthesizers actively commenting, sharing, rating and reacting. For each group of synthesizers, roughly 100 consumers read, watch, listen and enjoy

while participating only occasionally. All three of these groups have a valid place within the community. event forms. Just as we have built communities of physicians who speak openly with each other about our products, we have an opportunity to nurture and learn from consumer communities as well. First, we must listen with intent…Analyzing what you hear can reveal a gap in consumer awareness. What’s more, a number of tools have emerged to help consolidate the vast array of social media input, from free online evaluators like Intelliseek, to sophisticated and customized tracking services like Cymfony. Once marketers have a firm grasp on the language, attitudes, brand perceptions and key COLs in their consumer community, pharmaceutical company participation can range from targeted media placement to integration and empowerment. All approaches are open to branded or unbranded programs…

A Glimpse Under the Data Collection `Hood’: Behavioral, Social Graph, Ad Exchanges, Ad Optimization


As CDD explained to the FTC and data protection commissioners, advances in online ad data collection, selling and targeting raise significant privacy concerns. This rapidly evolving infrastructure of user data auctioning requires scrutiny and safeguards.  Here are some excerpts from jobs in the sector, which gives one a glimpse of what’s going on.

Director of Agency Development- NYC – eXelate

About eXelate

The eXelate Targeting eXchange is the world’s first and largest open marketplace for behavioral targeting data. Through participation on the eXchange, data buyers build an instant behavioral targeting function and optimize their campaign delivery, while data sellers gain insight on their audience, control over their data distribution, and build a new privacy–friendly income stream. The eXchange includes over 40 top ad network/agency buyers and dozens of leading publishers, who deliver targeting data on more than 170 million unique users each month.

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Account Manager – NYC – Netmining…

Netmining is a global provider of behavioral marketing solutions that are proven to increase conversion rates across websites, online advertising, email programs and offline sales channels. With a real-time profiling engine that understands each individual’s interests and buying propensity, Netmining enables companies to deliver highly relevant and personalized interactions across the entire customer lifecycle.
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Senior Account Manager – Social Targeting Data – NYC – Media6degrees: About Us

We are the first online advertising firm built from the ground up specifically to leverage “social graph” data. The power of this data is captured by the phrase “birds of a feather flock together.”  We have mapped the social graph interactions of nearly 75 million US consumers and are the first company to offer “social targeting” which allows marketers to fully exploit the network value of every individual customer with whom they interact while also significantly improving response rates on new acquisition campaigns.

Our platform employs proprietary cookies to map the social graph. Our core data used to map the social graph has long been part of the standard Internet advertising protocols for trafficking advertisements and has been fully integrated with both Yahoo’s RightMedia platform as well as the DoubleClick Exchange and is accessible to any of the thousands of major marketers who advertise through these vehicles.

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Senior Account Executive (2 Jobs) – NYC, SF – TARGUSinfo: 

Its unique identification, verification, qualification and location services enable retailers, call-center operators, Web-based marketers, communication service providers and others to dramatically increase the quality of their services and the effectiveness of their marketing. A privately held company, TARGUSinfo is headquartered in Vienna, Va. For more information, visit www.TARGUSinfo.com.

With a focus on delivering measurable, predictable results in a online environment, TARGUSinfo is defining tomorrow’s marketing standards by delivering a display advertising targeting solution to advertising networks, interactive advertising agencies, and publishers.  We currently have a large cookie-based audience solution based on verified offline data assets.

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Optimization Consultant, Ad Exchange – NYC – Google

you will be responsible for working with buyers and sellers on the Ad Exchange to optimize their experience (ie. manage yield or drive return on marketing investment). You will be responsible for partnering closely with Product Management, Engineering, Sales, and Services to build models, develop new ones, apply customer specific data, and develop insights.

When Privacy Groups Raise Money from Facebook, Google, and the companies they are supposed to hold accountable

Facebook’s COO Sheryl Sandberg is the industry draw for CDT’s 2010 fundraising event.  “Gold” sponsors of the “host committee” include Facebook, Google, Microsoft and AT&T.  “Silver” sponsors (and there’s a long list) include Adobe, NCTA, eBay, Verizon, Intel, AOL, Time Warner Cable, News Corp., Visa, Yahoo, Comcast and a bevy of law firms that work on privacy and related issues.  They include Manatt Phelps, Wilmer Cutler, Wilson Sonsoni, and Arnold and Porter.

It’s troubling–to say the least–when any consumer/public interest group takes funding from the industry/industries it is supposed to hold accountable.  Conflict of interest questions and concerns need to be posed whenever the group takes a position and has funding from parties connected to the issue (think about Facebook and Google’s recent privacy problems, let alone legislation and policies now before Congress and the FTC).  It’s great to have extra money.  But we suggest groups “just say no” to such special interest relationships.

Facebook Expands Big Brand Marketing Clout: Helping Starbucks to “get people to buy a muffin on a certain day”

The top execs at Facebook claim that the social network giant ad targeting apparatus is well understood by its users, and that they have secured their consent.  But I suggest few users understand the complexities of Facebook’s viral marketing and tracking system, let alone the new Facebook/Nielsen “Brandlift” initiative designed to demonstrate Facebook can deliver big for the biggest brands.  According to New Media Age:
More than 70 studies have been done in the US in the FMCG, retail, media and entertainment, telecoms, financial and automotive sectors. Nielsen and Facebook said 97% of these found a significant lift in at least one brand metric, while 85% reported an increase in at least two.  “Starbucks is a heavy advertiser on Facebook,” said [Trevor Johnson, head of strategy and planning EMEA at Facebook] Johnson. “We ran a campaign to get people to buy a muffin on a certain day and measured a 94% uplift in purchase intent.”…Facebook will apply the demographic data it already collects from its users to deliver results tailored to brands’ needs.

Civil Liberties, Consumer & Privacy Groups to FCC: Protect Privacy


The American Civil Liberties Union, Center for Digital Democracy, Consumer Action, Consumer Federation of America, Consumer Watchdog, Privacy Lives, Privacy Rights Clearinghouse, Privacy Times, and U.S. PIRG told the FCC in a filing 22 January 2010 that: “There are significant problems concerning the collection and use of personal data by companies, especially sensitive data and children’s data; (2) The FCC should not rely on industry self-regulatory models because they do not adequately protect consumer privacy; and (3) The principles and standards that should serve as the foundation of consumer privacy protection should be the Fair Information Practices, especially as they are implemented in the OECD Guidelines on data privacy… The FCC should consider all avenues it may use to protect consumers, including exercising its ancillary jurisdiction to address broadband privacy issues, and working with Congress and the Federal Trade Commission (“FTC”), which has substantial expertise in consumer privacy protection.”


To learn more, click here.


Where Does Google and Microsoft Really Stand–with the IAB and ad lobby or for Consumer Protection?

Both Google and Microsoft serve on the executive committee of the Interactive Ad Bureau, a trade association fighting against consumer privacy proposals in Congress and the FTC.  The IAB just sent a letter signed by other ad and marketing industry lobbyists opposing Obama and congressional proposals to expand the ability of the FTC to better protect consumers.  My CDD just sent emails to officials at both Google and Microsoft asking them to clarify where they stand on the IAB’s letter [see below].  Do our two leading online marketing leaders support financial and regulatory reform, including protecting privacy?  Or does the IAB letter–and Google and Microsoft’s own role helping govern that trade lobby group–really reflect their own position against better consumer protection? Not coincidently, the IAB’s PAC has expanded its PAC contribution giving to congress.

Why does the IAB and other ad groups want to scuttle a more capable FTC?  Think online financial products, including mortgages, pharmaceutical operated social networks, digital ads targeting teens fueling the youth obesity crisis, ads created by brain research to influence our subconscious minds, a mobile marketing system that targets us because it knows our location, interests and behavior.  The IAB is terrified that a responsible consumer protection agency will not only peek under the ‘digital hood,’ as the Obama FTC is currently doing.  But actually propose policies and bring cases that rein in irresponsible and harmful business practices.  So Microsoft and Google:  who are with?  Consumers or the special interest advertising lobby?
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letter to Google:  22 January 2010

Dear Pablo, Jane, Peter and Alan:

As you may know, the Interactive Advertising Bureau recently sent a letter  to Congress, along with other ad related groups, opposing the expansion of FTC regulatory authority as proposed in the Consumer Financial Protection Agency bill and related reauthorization [http://www.clickz.com/3636212].

Google serves on the executive committee of the IAB’s board.  For the record, does Google support IAB’s stance that, as news reports say, if the FTC is given additional enforcement and penalty-making authority, “the FTC could essentially act as an unelected legislature governing industries and sectors across the economy.”

If Google disagrees with the IAB’s letter, I ask that it make its position public as soon as possible.  I also respectfully request Google state its position regarding the Consumer Financial Protection Agency proposal, as well as its position on expanding FTC authority.

Regards,

Jeff Chester
Center for Digital Democracy
www.democraticmedia.org

letter to Microsoft:  22 Jan. 2010:

Dear Mike and Frank:

As you may know, the Interactive Advertising Bureau recently sent a letter to Congress, along with other ad related groups, opposing the expansion of FTC regulatory authority as proposed in the Consumer Financial Protection Agency bill and related reauthorization [http://www.clickz.com/3636212].

Microsoft serves on the executive committee of the IAB’s board.  For the record, does Microsoft support IAB’s stance that, as news reports say, if the FTC is given additional enforcement and penalty-making authority, “the FTC could essentially act as an unelected legislature governing industries and sectors across the economy.”

If Microsoft disagrees with the IAB’s letter, I ask that it make its position public as soon as possible.  I also respectfully request Microsoft state its position regarding the Consumer Financial Protection Agency proposal, as well as its position on expanding FTC authority.

Regards,

Jeff Chester
Center for Digital Democracy
www.democraticmedia.org

Facebook Boosts of its Brand Building Power, with Nielsen [“Brand Lift”] Research on the way to help

In a December 2009 interview in New Media Age, Facebook’s director for commercial marketing in the EMEA and UK market explained that [excerpt]:  CPMs on our home page are three or four times those of Yahoo’s. On click-through, the engagement levels we’re getting are 10-15 times that. Not 10% more, 10-15 times Yahoo’s click-through rates. This is where we’re selling to P&G and those big brands.  The other side of our business is performance: those little square boxes, ASUs [Ad Space Units], that appear everywhere except the home page. 80% of our inventory is driven through a self-service auction model. We’re on 50bn of them a month in the UK. That’s scale. And big brands are saying they’re getting more volume and lower cost than Google on Facebook right now…The big thing we’re bringing to the market in early Q1 is Nielsen-branded research, which will reveal what people are doing, using awareness consideration and favourability metrics that are important to branded advertising. We’ll be able to quantify this via Nielsen.

Tracking Mobile Users by Behavior and Race: Why the FTC Must Address Mobile Privacy ASAP

Here’s a brief excerpt from the “The mobiThinking guide to mobile advertising networks 2010.”  Our emphasis.

Microsoft Mobile Advertising: Targeting capabilities include device, demographic (gender, age, household income), geographic and behavior.

Advertising.com/AOL: Full suite of targeting options, including device, browser, operating system, carrier, on/off-deck, geography, time-segment, content, and multiple demographic combinations.

Nokia Interactive Advertising: Demographics, location, handset type, and in the US by channels (e.g. auto, news, sports.

Quattro Wireless: a) contextual: media type, channel, publisher; b) demographic: gender, age, ethnicity, education; c) location; d) mobile: carrier, device class, manufacturer, model, features, operating system, browser; e) frequency of exposure.

Jumptap: Jumptap offers 64 different targeting options including: demographic, geographic location, carrier, on/off-deck (operator portal), device types and browser, time of day, day of week, content category and frequency controls. These targeting parameters are derived from multiple data courses, including contextual information and true carrier subscriber information. Premium brand advertising guarantees the ad will appear on certain sections of chosen site at the time specified.

Millennial Media: Audience targeting: Millennial can uniquely identify a user across all sites on the network – they are grouped into audiences, based on their observed behaviors on sites, participation and review of click-stream data, so campaigns can be targeted at specific audiences. (Millennial discloses these techniques, with an opt-out in accordance with the Self-Regulatory Principles for Online Behavioral Advertising, July 2009). Advertisers can also do Run of Network (RON) campaigns or target by channel, custom subnet, takeover, network blocks or demographic. There is also targeting via geography, carrier, handset model/manufacturer/operating system, handset features, age of device, time of day, location, Wi-Fi, etc.

Which “Network/Entertainment” Company is Expanding its use of Neuromarketing? NeuroFocus Looks for Specialist to help that showbiz client “Develop actionable insights from neurological studies”

Companies that rely on influencing brain behavior in order to achieve marketing goals are treading on a very slippery regulatory slope.  Nielsen-backed NeuroFocus is currently searching for a “Partner” in its “Consulting Practice.”  That person will be “responsible for the development and presentation of neurological studies commissioned by our key client in the network/entertainment industry…Of primary focus will be…developing insights from the neurological study results to benefit the client leading to a lasting relationship. Summary of essential job functions:


• Develop actionable insights from neurological studies
• Present results of neurological studies directly to clients
• Deep understanding of entertainment industry / network & cable television industry
• Experience in management consulting, market research, and advertising…

NeuroFocus, Inc. is the market leader in bringing neuroscience to the world of advertising, messaging, packaging, and product development. NeuroFocus clients include Fortune 100 companies across consumer package goods, food and beverage, entertainment, financial services, automotive, consumer electronics and retail sectors. NeuroFocus clients also include major companies in the TV and Motion Picture industries.”