When did managing a viewer's privacy become as complicated as a Rube Goldberg device? That's the first thing that occurred to me when I started thumbing through the Interactive Advertising Bureau's (IAB) new "Project Crosswalk 2.0" report delineating the complexity of modern day privacy compliance for the burgeoning CTV advertising marketplace.
The report, which was released this morning, contains 59 eyecharts in 48 pages delineating the back-and-forth data exchanges necessary to comply with current privacy regulations in order to process various CTV advertising buys.
The one depicted above illustrates a programmatic data exchange for an RTB ad buy utilizing publisher managed ad inventory.
I'm not sure why I settled on that one to illustrate the current state of TV advertising complexity, because many of them are equally as complicated. But for good reason.
The report is probably the most accurate current compendium organizing the complexity of a multitude of state consumer privacy laws layered on top of what already was a relatively complex audience targeting and advertising exchange process underlying the modern-day programmatic CTV marketplace.
And for those of you who are wistful for the comparatively simpler times when Nielsen "families" were good enough proxies for understanding who might be sitting in front of a screen with your ad on it, well, this isn't your father's Oldsmobile commercial viewing experience.
In fact, the report has a whole section making that point by attributing much of the complexity to the fact that today's modern marketplace still operates by a 1988 law designed to protect American viewers' privacy in the age when Blockbuster Video still was a thing.
In fact, the IAB report describes that federal Video Privacy Protection Act as a "Blockbuster era law snarling modern CTV advertising."
That law was conceived at a time when people feared the video titles they rented -- even the ones on the racks of the back rooms of Blockbuster and other video rental stores -- might become public and cause all sorts of embarrassment.
That may seem quaint in an era of Netflix meets Pornhub, but the real point shouldn't be that our regulatory mindset is stuck in simpler times. It should be that the modern era of consumer data-exposure vectors is itself so complex that it requires new ways of thinking about consumer privacy protection. Even if it makes your head hurt.
I mean, we literally watch TVs that are listening to what's going on while we are watching them -- never mind all the other data capture and appending that can go on through the daisy chain of data enrichment from end-to-end by the time an ad was determined to be the optimum one to be served in front of someone who may be sitting in front of a TV set.
As far as I know, no Blockbuster Video store ever listened to me, preserved and shared my data back in the day.
Maybe that's because there was a simple law prohibiting it.
Or maybe because it was just creepy and defied common sense.
Robert Bork, remember him? The 1988 law was written to protect nominees to the Supreme Court, less so the general public.
Almost every "smart" TV requires you to connect to a network and share your behavior just to set up the TV. They can start there by making this an opt-out feature.
And an additional reason why I refuse to purchase a TV with a microphone or camera built in "for my convenience."