Are We CLEAR? Looking Through 'Transparency'
The privacy icons are here. The privacy icons are here.
After a protracted period of collaboration, development and testing, the long-promised proposals for applying greater transparency to online data gathering by ad networks and Web sites finally emerged this week. We are that much closer to getting a standard set of icons and messaging for ads and sites that consumers can use to monitor and control the data that are being collected on them. Or at least that is the hope.
The IAB, NAI, along with American Association of Ad Agencies, Association of National Advertisers, Direct Marketing Association and Council for Better Business Bureaus started this process last summer when they formally responded to the FTC's call for industry self-regulation with "Self-Regulatory Principles for Online Behavioral Advertising." The original 42 page document is here.
This week the IAB and the NAI jointly released proposed specifications for how ads and sites can notify consumers that their online behaviors are being tracked or that past activities have been used to deliver a specific ad. Dubbed CLEAR for Control Links for Education and Advertising Responsibility, the specs call for icons to be placed inside or near ads that reveal information about the third party collecting the data. The IAB/NAI document outlines a set of metadata tags that should accompany these icons to reveal their source.
The specs are provided in an 18-page document also available at the IAB.
We'll cut to the chase, however. Our tendency in this insular ad industry is to come at these proposals asking, what does that mean for me. But let's walk through the proposed icon-driven system more from the user's perspective, or even the ad client's. The process begins for the consumer with a 12x12 pixel Ad Marker that resembles a computer "Power On" emblem with an "i" in the center, plus accompanying text label. The notification can be in the ad unit itself or adjacent, in the spot where many publishers now put an "Advertisement" label. The proposed labeling of the icon can be "Why did I get this ad?," "Interest Based Ad" or "Ad Choices." The ad association consortium and Future of Privacy Forum worked together on devising and testing these labels, which apparently emerged as the ones consumers themselves found most clear. Clicking on the ad brings up an interstitial either as an overlay or a new window, with a landing page that contains metadata about the advertiser and the network.
The important point about the system is that this metadata travels with the ad itself, so the consumer is able to see the sources attributed whenever and wherever they get the ad. It seems to me that the metadata required in this model has some important implications for the entire value chain. In the example the IAB/NAI provide, a Southwest Airlines ad pops up an overlay that visualizes the metadata. The data set includes first the advertiser name as well as a link to the advertiser. The IAB/NAI document suggests that the link provided for the advertiser go to a home page or to a page that outlines the client's ad practices and partners.
I wonder how some brands will respond to this piece of the model, since many advertisers like to use behavioral targeting without necessarily talking about it or having their brands identified with the practice. This model pretty much ties a client to the practice of BT. From the perspective of transparency, this is a good thing, of course. But it seems to force an issue that has been lying in wait for a number of years - how accountable will brands want to be about their ad and marketing practices, and how will this affect their ad buying behavior?
Of course, most consumers will be in the weeds by this point. Distinguishing between an ad network and a data company is second nature to some of us, but my guess is that most people will not see the distinction, because doing so really does require some understanding of how online ad technology works. In the example from the IAB/NAI document, the Network (in this case Yahoo) is labeled as "Delivered By." The matcher category is labeled as "Customized By" (in this case also Yahoo) and it is explained in a sentence: "The ad was customized for your browser based on past activity." Maybe an explanation like that will help some people distinguish between network and data service, but I can imagine most people wondering what part of the chain they are opting out of if they click through on one or the other.
Which is not to say that this proposal for universal ad signage and messaging is flawed. Actually, it seems refreshing -- especially in making every ad carry highly visible metadata with it and in holding the advertiser itself accountable for ad practices. But even in a first pass of this system, it is clear that transparency has to have consequences, perhaps some of which we haven't even considered yet.