Damian Scragg, Evidon - Making Privacy Sexy

Confidential | Draft for Discussion Purposes Only 2012 Evidon, Inc. All Rights Reserved.


See, understand and control data online.


Evidon empowers consumers and businesses to see, understand and control data online.


Making privacy sexy…


consumers

Protect consumers’ privacy


• 6+ million downloads

• 1.6+ million active weekly panel members

• Only comprehensive tracking code library


Protect consumers’ privacy


businesses

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


Protect your business Everywhere

AdChoices


Protect your business Everywhere


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


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.


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

http://www.ffw.com/pdf/cookie-consent-tracking-table.pdf









May 25th is the beginning and not the END!

…..so what does it mean for all of you?


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


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


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


Drops 8 cookies

Has no opt-out

Takes 86ms to load

Uses flash cookies


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



Disclose + get consent


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


Explicit Consent Option

23


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


Confirmation Message

24


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


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


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


In Summary

1. Audit and continually monitor tracking across sites

2. Review your privacy policy & consider a cookie policy

3. Deploy consent solutions

27


Thank You.

Damian Scragg

Managing Director, UK

[email protected]

Technology

Damian Scragg, Evidon - Making Privacy Sexy