Behavioral Advertising

Public Comments: January 2012 - Regarding Face Facts: A Forum on Facial Recognition

The World Privacy Forum appreciates the opportunity to comment on the issue of facial recognition pursuant to the FTC Face Facts Workshop held on December 8, 2011. [1] The World Privacy Forum spoke on Panel 4 of the workshop, and those comments are already on the record. In these written comments, we would like to submit several key documents for the record and reaffirm several ideas from the workshop. The documents we are including as part of these comments include the World Privacy Forum’s groundbreaking report on digital signage, The One Way Mirror Society. Also included as part of these comments are the consensus privacy principles for digital signage installations that were signed by the leading US consumer and privacy groups.

Report: Many Failures: A Brief History of Privacy Self Regulation | Section: Introduction and Summary

Current online privacy debates focus on respecting the privacy interests of Internet users while accommodating business needs. Formal and informal proposals for improving consumer privacy offer different ideas for privacy regulation and privacy self-regulation, sometimes called codes of conduct. [1] Some in the Internet industry continue to advance or support ideas for privacy self- regulation. Many of these same players proposed and implemented privacy self-regulatory schemes that started in the late 1990s.

Report: Many Failures: A Brief History of Privacy Self-Regulation | Section: Industry-Supported Self-Regulatory Programs for Privacy

This section offers a historical review of privacy self-regulation that occurred in the years just before and just after 2000. For a variety of reasons, it is not necessarily fully comprehensive. Some self-regulatory efforts may have disappeared without a trace. Activities within existing trade associations are difficult or impossible to assess from evidence available to those outside the associations. However, this discussion captures the leading organizations of the time. [13]

Report: Many Failures: A Brief History of Privacy Self-Regulation | Section: Government Privacy Self-Regulatory Activities

This section reviews several other privacy self-regulatory activities that share some characteristics with the industry self-regulatory programs discussed above, but these activities differ in various ways. The most noticeable differences are the role of the government in the programs. The Department of Commerce is involved in the Safe Harbor Framework, and the Federal Trade Commission is involved in the Children’s Online Privacy Protection Act.

Report: Many Failures: A Brief History of Privacy Self-Regulation | Section: Conclusion

Is there any reason to think that privacy self-regulation will work today when it did not work in the past? Privacy self-regulation done in the same way that it has been done in the past, without sufficient consumer participation, and with the same goals of simply evading real regulation and effective privacy controls will continue to fail.

WPF comments about Personal Health Records and online advertising

Health privacy -- The World Privacy Forum filed comments today about how medical records and other health information is intersecting with online advertising and online activities. The WPF comments were filed with the Department of Health and Human Services in response to its request for comments on personal health records, privacy, and social media.

Top Ten Opt Out list updated

Opt-out and how-to -- The popular WPF Top Ten Opt Out List has been newly updated. We have added a new section to our list with step by step details on how to opt out of RapLeaf. We encourage consumers to view any of their profiles that exist at RapLeaf and to opt out of RapLeaf permanently. We have also updated the phone numbers and other information on the rest of our opt out list. To see more, visit our Opt Out List.

Digital Signage Privacy Principles for Consumers: Nation's leading consumer groups release new privacy principles

Digital Signage Privacy Principles -- The nation's leading consumer and privacy groups released a set of baseline consumer privacy principles to be included in digital signage networks. The principles were released at the Digital Signage Expo in Las Vegas, Nevada, where World Privacy Forum executive director Pam Dixon spoke about the principles to a large group of digital signage industry professionals.

Digital Signage Privacy Principles: Critical policies and practices for digital signage networks

Download Digital Signage Privacy Principles (PDF) or Read the Principle below ----- February 25, 2010 New forms of sophisticated digital signage networks are being deployed widely by retailers and others in both public and private spaces. Capabilities range from simple people-counting sensors mounted on doorways to sophisticated, largely invisible facial ...

WPF to speak at FTC Privacy Roundtable

FTC Privacy Roundtable -- Thursday, January 28, WPF Executive Director Pam Dixon will be speaking at the FTC's Privacy Roundtable about the privacy implications of digital signage networks and will be specifically discussing the new report: The One-Way Mirror Society: Privacy Implications of the New Digital Signage Networks. Few consumers, legislators, regulators, or policy makers are aware of the capabilities of digital signs or of the extent of their use. The technology presents new problems and highlights old conflicts about privacy, public spaces, and the need for a meaningful debate.

WPF Report: One-Way-Mirror Society - Privacy Implications of the new Digital Signage Networks

This 2010 WPF report, The One Way Mirror Society, explores new forms of sophisticated digital signage networks and their privacy implications in the US and other countries. Digital signage networks are being deployed widely by retailers and others in both public and private spaces. From simple people-counting sensors mounted on doorways to sophisticated facial recognition cameras mounted in flat video screens and end-cap displays, digital signage technologies are gathering increasing amounts of detailed information about consumers, their behaviors, and their characteristics.

One-Way-Mirror Society: Introduction - What is digital signage and why care about its privacy implications?

The digital signage networks this report addresses are bi-directional. These networks give information to viewers while they capture information from viewers and send it back to a home base. In the digital signage industry, the new technologies are often compared to the interactive signs from the movie Minority Report. [1] In the movie, large-screen video billboards recognized individual consumers and delivered personalized advertisements to each person. The movie version of the digital signs and billboards relied on an iris scan to customize the ads. Today’s modern digital signs rely on advanced video analytics and sophisticated cameras and sensors.

One-Way-Mirror Society: Overview of key digital signage capabilities in place today

The best way to understand the capabilities of digital signage today and how it is being used is to see the digital signage industry’s newly minted Recommended Code of Conduct for Consumer Tracking Methods (See Appendix A for complete document). This document on consumer tracking methods in digital signage was written and agreed upon entirely by industry members, without any participation by consumer representatives. The document reflects the advances in technology in this area and where the possibilities for abuse lay. The opening of the document reads:

One-Way-Mirror Society: Lower and Medium Privacy Risk Consumer Tracking Technologies

Heat maps and path tracking technologies essentially generate maps of where consumers spend the most time standing and walking in stores. (Figure 2). One product, PathTracker, uses RFID chips for large store tracking, and video tracking technology for smaller stores or sub-areas within stores.

One-Way-Mirror Society: High Privacy Risk Consumer Tracking Technologies

Facial recognition technology was initially developed for security purposes, but it has found a new use in digital signage for marketing and ad targeting purposes. Essentially, the process is that a camera captures an individual’s image, then checks it against algorithms that analyze at least 80 facial characteristics, such as distance between eyes, length of the face, width of the face, depth of eye sockets, and so forth. [48] Layers of algorithms are used to crunch the facial information into determinations about a person’s age bracket, gender, and ethnicity. The next efforts are going toward coding the facial expressions of shoppers to “capture their emotional reactions to in-store environments.” [49]

One-Way-Mirror Society: Consumer Responses to Digital Signage and Privacy Issues

Few consumers are aware that watching a video screen or interacting with a kiosk may mean they are being recorded and having their behavior, gender, age, and ethnicity analyzed. As a result, there has not been a robust public discussion of how consumers feel about these technologies.

One-Way-Mirror Society: What are the specific privacy issues posed by digital signage networks / what risks exist?

Security Camera Footage: Repurposing footage for marketing and profit Perhaps the most egregious repurposing of data is the use of security camera footage for store marketing purposes. From the industry literature, this appears to be an established business practice at this point. It is one that needs to be examined closely.

One-Way-Mirror Society: Recommendations

There is no public awareness of the capabilities of digital signage, and that has to change before for any debate over regulation or legislation can start. Nevertheless, it is possible to identify from other privacy arenas the types of standards that should be considered for users of digital signage. Full recommendations will only be possible at a later stage. Here are some preliminary ideas.

One-Way-Mirror Society: Conclusion

New forms of sophisticated digital sign networks are being deployed widely by retailers and others in both public and private spaces. Few consumers, legislators, regulators, or policy makers are aware of the capabilities of digital signs or of the extent of their use. The technology presents new problems and highlights old conflicts about privacy, public spaces, and the need for a meaningful debate. The privacy problems inherent in digital networks are profound, and to date these issues have not been adequately addressed by anyone.

One-Way-Mirror Society: Appendix A - POPAI Recommended Code of Conduct for Consumer Tracking Methods

The following document is the recommended code of conduct for businesses engaging in consumer tracking. The document is entirely non-binding, and was created entirely by industry participants. The document is reproduced here in full with no changes. Best Practices: Recommended Code of Conduct for Consumer Tracking Methods

World Privacy Forum files comments on behaviorally targeted ads online; requests separate rulemaking for sensitive medical information

Behaviorally targeted advertising | FTC proposed rules -- The World Privacy Forum filed comments in response to the Federal Trade Commission's proposed self-regulatory guidelines for companies targeting online advertising to consumers based on consumer behaviors. The WPF requested a separate, formal rulemaking process for determining how sensitive medical information should be handled online regarding behaviorally targeted advertisements. The WPF also discussed genetic data and requests for genetic tests, and noted that genetic information should be included in any definition of sensitive medical information. The WPF reiterated that the definition of personally identifiable information should include IP address, and encouraged the FTC to work from a rights-based approach regarding online advertising. The WPF also urged the FTC to include all fair information practices in any self-regulatory regime, and to enforce the regime directly.