Confidential | Draft for Discussion Purposes Only 2012 Evidon, Inc. All Rights Reserved.
Confidential | Draft for Discussion Purposes Only 2012 Evidon, Inc. All Rights Reserved.
See, understand and control data online.
Confidential | Draft for Discussion Purposes Only 2012 Evidon, Inc. All Rights Reserved.
Evidon empowers consumers and businesses to see, understand and control data online.
Confidential | Draft for Discussion Purposes Only 2012 Evidon, Inc. All Rights Reserved.
Making privacy sexy…
Confidential | Draft for Discussion Purposes Only 2012 Evidon, Inc. All Rights Reserved.
consumers
Protect consumers’ privacy
Confidential | Draft for Discussion Purposes Only 2012 Evidon, Inc. All Rights Reserved.
• 6+ million downloads
• 1.6+ million active weekly panel members
• Only comprehensive tracking code library
Confidential | Draft for Discussion Purposes Only 2012 Evidon, Inc. All Rights Reserved.
Protect consumers’ privacy
Confidential | Draft for Discussion Purposes Only 2012 Evidon, Inc. All Rights Reserved.
businesses
Protect your business
Confidential | Draft for Discussion Purposes Only 2012 Evidon, Inc. All Rights Reserved.
Protect your business
• Who are they? What do they do?
• How often do they appear?
• How do they affect my site performance?
• Does their opt-out work?
• Is my site “cleaner” than my peers?
Know your site
Confidential | Draft for Discussion Purposes Only 2012 Evidon, Inc. All Rights Reserved.
Protect your business Everywhere
AdChoices
Confidential | Draft for Discussion Purposes Only 2012 Evidon, Inc. All Rights Reserved.
Protect your business Everywhere
Confidential | Draft for Discussion Purposes Only 2012 Evidon, Inc. All Rights Reserved.
EU ePrivacy Directive
A LAW requiring:
• Notice when collecting/using a European consumers’data
• The means to control how their data is used
• For all forms of tracking, not just cookies and/or online behavioural advertising (OBA)
• Consent
11
Confidential | Draft for Discussion Purposes Only 2012 Evidon, Inc. All Rights Reserved.
Where The Law Stands
• EU law ratified
• Each member state required to pass similar law
• May 25 UK deadline!
Law passed (blue)
12
Law proposed (yellow)
Norway
Iceland
Italy
Poland
Sweden
Ireland
Switzer land
Czech Republic Slovakia
Hungary
Lithuania
Latvia
Moldova
Bulgaria
Estonia
France
Nether lands
Bosnia
Slovenia Croatia
Denmark
Finland
Serbia
Albania Macedonia
Montenegro
Cyprus
Po
rtu
gal
Belgium
United Kingdom
Germany
Austria
Romania
Greece
Spain
Lux.
Confidential | Draft for Discussion Purposes Only 2012 Evidon, Inc. All Rights Reserved.
Consumer CONSENT Required But may be interpreted differently per territory
Implied
Could be satisfied by user simply leaving default privacy settings as they are.
Currently: • Bulgaria
• Czech Republic
• Denmark
• Estonia
• Finland
• Germany*
• Hungary
• Ireland
Explicit
Could include proactive browser setting, collection of opt-in cookie before data collection/use, etc.
Currently: • Cyprus
• France*
• Greece
• Latvia
• The Netherlands*
• Poland
• Portugal
• Romania
• Lithuania
Source: Field Fisher Waterhouse Cookie Consent Tracking Table, February 2012, http://www.ffw.com/pdf/cookie-consent-tracking-table.pdf, Evidon analysis. * Discussions between industry and regulators still ongoing
• Italy
• Luxembourg
• Malta
• Slovakia
• Slovenia
• Spain*
• Sweden
• United Kingdom*
Currently unclear: Austria, Belgium, Iceland, Liechtenstein, Norway
13
Confidential | Draft for Discussion Purposes Only 2012 Evidon, Inc. All Rights Reserved.
May 25th is the beginning and not the END!
…..so what does it mean for all of you?
Confidential | Draft for Discussion Purposes Only 2012 Evidon, Inc. All Rights Reserved.
Site owners: the law applies to you
As long as data is collected, used, same compliance obligation
15
…storing of information, or the
gaining of access to information already stored, in the terminal equipment of a subscriber or user
is only allowed on condition that
the subscriber or user concerned
has given his or her consent, having
been provided with clear and comprehensive information, in
accordance with Directive 95/46/EC....
DIRECTIVE 2009/136/EC OF THE
EUROPEAN PARLIAMENT AND OF THE COUNCIL
of 25 November 2009
Confidential | Draft for Discussion Purposes Only 2012 Evidon, Inc. All Rights Reserved.
Take action now!
1. Audit and continually monitor tracking across sites
2. Review your privacy policy & consider a cookie policy
3. Deploy consent solutions
16
Confidential | Draft for Discussion Purposes Only 2012 Evidon, Inc. All Rights Reserved.
The Audit
• First step requested by ICO and CNIL
• The Audit is the responsibility of the site owner
• Not just cookies – all forms of tracking!
• Should not be a one off process
• Continual monitoring should be best practice
17
Confidential | Draft for Discussion Purposes Only 2012 Evidon, Inc. All Rights Reserved.
Drops 8 cookies
Has no opt-out
Takes 86ms to load
Uses flash cookies
Confidential | Draft for Discussion Purposes Only 2012 Evidon, Inc. All Rights Reserved.
Gaining Consent
• Empower consumers; get their consent to be tracked
• 1st & 3rd party tracking
• Only a limited field of strictly necessary cookies/tracking
• Comply with privacy regulations
• Grow your business
19
Confidential | Draft for Discussion Purposes Only 2012 Evidon, Inc. All Rights Reserved.
Protect your business
Disclose + get consent
Confidential | Draft for Discussion Purposes Only 2012 Evidon, Inc. All Rights Reserved.
Googlehttp:/ / www.gardenandgrow.com
Garden and Grow
About Cookies on this site:
Our site uses cookies and other technologies so that we and our partners can remember you,
make the content you see more relevant and generally improve your browsing experience. Read
more about cookies here. Through our Cookie Consent Wizard, available on every page on our
site, you can see a complete list of these cookies and technologies and set your preferences.
Remove message
21
Cookie Consent
Confidential | Draft for Discussion Purposes Only 2012 Evidon, Inc. All Rights Reserved. 22
Confidential | Draft for Discussion Purposes Only 2012 Evidon, Inc. All Rights Reserved.
Explicit Consent Option
23
Googlehttp:/ / www.gardenandgrow.com
Garden and Grow
We need your consent to proceed!
Our site uses cookies and other technologies so that we and our partners can remember
you, make the content you see more relevant and generally improve your browsing
experience.
For more details about how information is accessed and stored on this site see our
Privacy Policy.
Privacy Controls by Evidon Why am I seeing this notice?
Agree and Access Site
To see a complete list of these cookies and
technologies and to set your cookie preferences,
access our Cookie Consent Wizard:
When you proceed to access our site, we will use
such cookies and technologies as presented in the
Cookie Consent Wizard. Your consent, which you
can withdraw at any time, will be set with a cookie
from our privacy partner, Evidon.
Cookie Consent Wizard
Confidential | Draft for Discussion Purposes Only 2012 Evidon, Inc. All Rights Reserved.
Confirmation Message
24
Googlehttp:/ / www.gardenandgrow.com
Garden and Grow
We need your consent to proceed!
Our site uses cookies and other technologies so that we and our partners can remember
you, make the content you see more relevant and generally improve your browsing
experience.
For more details about how information is accessed and stored on this site see our
Privacy Policy.
Privacy Controls by Evidon Why am I seeing this notice?
Agree and Access Site
To see a complete list of these cookies and
technologies and to set your cookie preferences,
access our Cookie Consent Wizard:
When you proceed to access our site, we will use
such cookies and technologies as presented in the
Cookie Consent Wizard. Your consent, which you
can withdraw at any time, will be set with a cookie
from our privacy partner, Evidon.
Cookie Consent WizardThank you for providing your consent!
Remember that you can withdraw your consent at any time with our Cookie Consent Wizard, available on every page.
Cookie Consent Wizard
Confidential | Draft for Discussion Purposes Only 2012 Evidon, Inc. All Rights Reserved.
Person clicks on
a car ad and
lands on a
car website.
Tag Manager loads
a relevant tracker tag
(e.g., a Data Aggregator,
which adds this person
to its “auto intender”
segment).
Tag Manager tells
Evidon about that tag…
…so Evidon can notify
the person that the Data
Aggregator has collected
info about them.
2
1 3
“Data Aggregator
has collected info
about you!”
4 If the person takes some
action, e.g., opts out,
Evidon tells Tag Manager
so, the next time it sees
that user, it doesn't’t load
that Data Aggregator.
Evidon + TagMan = simple workflow and tag control for site
• Simplicity: site notice auto-populates
• Consumer preference more assured— their choices communicated to both tracker and site/tag manager
Confidential | Draft for Discussion Purposes Only 2012 Evidon, Inc. All Rights Reserved.
Site Owner Obligations – managing stakeholders
• Site Owners control only some of the tracking that appears on their websites
• Ensure that your tech, agency and network partners are disclosing all of the tracking that they are carrying out
• Request that companies serving ads directly to your site – networks, tech providers are displaying the AdChoices icon within their ads
• Where you are trafficking your own campaigns – be sure to traffic the AdChoices icon
• Ensure your AdChoices disclosure gives “clear and comprehensive information” and that you have a consent mechanism in place
26
Confidential | Draft for Discussion Purposes Only 2012 Evidon, Inc. All Rights Reserved.
In Summary
1. Audit and continually monitor tracking across sites
2. Review your privacy policy & consider a cookie policy
3. Deploy consent solutions
27
Confidential | Draft for Discussion Purposes Only 2012 Evidon, Inc. All Rights Reserved.
Thank You.
Damian Scragg
Managing Director, UK