Wednesday, April 29, 2009

FTC Weighs In on Behavioral Advertising

The current issue of Target Marketing magazine notes that:

"The Federal Trade Commission recently released self-regulatory guidelines on online behavioral advertising. Here are some of the highlights of what the FTC said marketers should abide by:

• Transparency and Consumer Control: Every site that collects data for behavioral advertising should provide a clear, concise, consumer-friendly and prominent statement. This statement should inform consumers that data is being collected for use in providing them with advertising about products and services tailored to their interests, and that consumers have a choice about whether their information is collected for behavioral advertising. Lastly, the FTC encouraged marketers to develop alternative methods—not necessarily just Web site-based policy statements—for providing disclosure and choice.
. . .
• Affirmative Express Consent to (or Prohibition Against) Using Sensitive Data for Behavioral Advertising: While the FTC expressed support for developing standards that define the term 'sensitive data,' the agency did state that the principle of affirmative express consent be applied to any use of sensitive data for behavioral advertising. Alternately, the commission states such data be prohibited from behavioral advertising uses."

The article goes on to note that "On the industry trade association side, the Direct Marketing Association, Interactive Advertising Bureau, American Association of Advertising Agencies, Association of National Advertisers and Better Business Bureau are working jointly on additional and forthcoming self-regulatory standards."

In the heyday of database marketing prior to the Internet (circa 1985 - 1995), behavioral advertising was a given -- but as an industry technique, not a subject of public discussion. The only question was how best to model, crunch, interpret and act on the data. Of course, with the advent of today's Internet marketing environment, the entire subject is much more fraught with privacy issues, which are themselves a fraught topic.

I agree with the article's conclusion: "the reality is that the new data-driven market shift will require us to respond with reasonable and sound privacy/security safeguards that take into account a self-regulatory landscape that must evolve as new channels and new business models continue to grow in the still-infant interactive age." In short, transparency and consumer-centric decision-making are the high road going forward. Nothing revolutionary there... except that many companies find that adhering to such standards is more difficult than it appears.

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