This is the summary of a behavioral targeting article by Saranga Komanduri, et al. You can get the pdf of the behavioral targeting article here: AdChoices? Compliance with Online Behavioral Advertising Notice and Choice Requirements
Online behavioral advertising is the practice of tracking consumers activities online to target advertising. Part of the responsibilities of companies engaging in online behavioral advertising is to listen to the privacy concerns of their consumers. Thus, in 1999, the Network Advertising Initiative (NAI) was created. Now, 66 companies are members of the NAI and they offer services for consumers to opt-out of online behavioral advertising. Another set of organizations formed the Digital Advertising Alliance (DAA) and they too have set principles of self regulation for online behavioral advertising.
The FTC determines what the next step is, and this study helps by investigating how effective opt-out and notices are. This paper also studies if the regulations implemented by DAA and NAI are being followed by several websites.
Online Behavioral Advertising
With online behavioral advertising, users are tracked to give them advertisements that are relevenant to their interests. Cookies are used to do the tracking. Despite its effectiveness, privacy concerns are being raised because data is being collected in secret, and this can create profiles of users tagged with sensitive personal information.
DAA and NAI Principles
DAA has seven principles. Education Principle (to main the website of DAA as an educational website), Transparency Principle (inspect ads and websites as they share certain info), Consumer Control Principle (provide opt out mechanism), Security Data Principle (data security requirements), Material Changes Principle (require companies consent before making changes), Sensitive Data Principle (steps for handling sensitive data), and Accountability Principle (develop compliance programs).
These are the same principles to NAI, along with additional principles that are irrelevant to the study.
Non-contextual ads were looked for in 100 websites, and 400 pages of these websites. 164 of these pages are monitored by the NAI members. The enhanced notice requirement requires the notice to be in the same page that contains the behavioral ads, but upon investigating these 164 pages, only 35 percent put enhanced notices, which is a huge compliance gap. The study further sees most of these enhanced notices are from the advertisers, the companies purchasing the ads, and not the members of NAI.
Implications for Public Policy