Looking Back and Moving Forward – My Thoughts After Six Months at NAI
After six months serving as NAI Executive Director, I am proud and inspired by who we are, what we’ve accomplished and where we are headed. I hope you find yourself similarly inspired and thank you for the collaborative work we’ve done together to achieve these goals.
First, the NAI couldn’t deliver on our mission without our committed members and team. Fortunately, member and team growth has been strong and diverse. This is allowing the NAI to expand our vision in order to address the increased need of members by company type, geography and domain. As we approach our 100th member, our roster now includes the largest ad networks, as well as DMPs, DSPs, SSPs, exchanges, analytics providers, and other business models. We’ve also expanded our footprint to cross many borders: Applications are being reviewed from non-U.S. based companies and networks focused on the mobile advertising ecosystem. The NAI staff roster is also stronger than ever.
Earlier this year, NAI issued our 2011 compliance report which demonstrated that overall, our member companies continue to meet the obligations of the NAI Code and to adopt best practices even where not required by the Code. The report also revealed:
- Member companies included in the report don’t use, or permit others to use, OBA data for purposes other than marketing.
- Evaluated member companies do not specifically target children under 13.
- Reporting companies did not use or seek to use sensitive consumer data as defined by the NAI Code for OBA purposes. In fact, we learned that our members are bringing increased transparency to all health-related targeting by disclosing all interest categories related to health in accordance with the NAI’s new health transparency policy.
- Evaluated member companies do not collect PII for OBA purposes, and they have policies and protections in place to prevent the inadvertent collection of this data.
We are proud and grateful for the innovative and effective advertising services our member companies provide to advertisers, publishers, and online consumers. As an organization, we support the dynamic and free content and services enjoyed by consumers online every day.
A core philosophy is emerging at NAI: We are a place to explore, discuss and champion industry best practices with respect to online privacy and data management. We are not here just to satisfy regulators or engage in privacy window dressing. We are here because responsible data management and respect for consumer choice is the right thing to do. Responsible and transparent business and data management practices promote consumer trust and confidence. The NAI recognizes that the evolving business models and rapidly changing technologies of the online environment present new issues with respect to privacy. We are not deterred by these challenges, but excited to tackle them and to demonstrate that innovation and privacy are not a zero sum game.
Like a comprehensive privacy management program, a self-regulatory code of conduct is never a finished product. To be effective and relevant, it requires an ongoing assessment. Thus, we are in the process of updating the NAI Code. As we update our Code, we are looking to other initiatives being implemented by DAA, MMA, and other associations as well as guidance issued by the FTC and the Administration. A fundamental principle underlying the NAI Framework being updated is that companies should implement different safeguards and obligations for different categories of data, taking into account the sensitivity of the data and the proposed use of the data. This basic principle, which has long been recognized by the NAI, is supported by the FTC Privacy Report and The Commerce Report, which explicitly acknowledges that privacy protections should not be applied in a “one-size fits all” approach, but should be flexible, scalable, and take into account context.
NAI will be launching our new website next month. It will reflect our belief in transparency and our commitment to consumer education. We’re working hard to make it easier for consumers to make informed decisions about the collection and use of data for online behavioral advertising. We believe that interest based advertising offers consumers an amazing experience but those consumers who would like to opt out of OBA should be able to exercise that choice – and easily.
We’ve also tremendously improved and expanded our first-rate compliance program. We now have more staff, enhanced compliance requirements, and extensive continuing education programs for NAI member companies. As the NAI expands in both size and scope, the need for a robust technical compliance program is increasingly evident. To that end, we are developing a suite of technical compliance tools and procedures that more quickly and accurately identify potential compliance issues. These tools and procedures will accomplish three main objectives:
- Automate the discovery and documentation of known compliance concerns;
- Provide accurate forensic data for discovery and examination of edge-case compliance concerns; and
- Increase transparency with the public and consumer advocates.
Over these past six months, we’ve also been able to improve and enhance communication with our members. In fact, we’ve already provided over 10 member calls in 2012 on NAI strategy and vision, Do Not Track, and international privacy issues. And there’s more to come.
While this rearview mirror inspires me for our journey ahead, there are significant challenges facing the NAI and our member companies. First and foremost are the ongoing discussions at W3C around what has been unfortunately and incorrectly labeled as “Do Not Track.” Indeed, this week I am in Seattle for a three day face-to-face meeting of the W3C Tracking Protection Working Group. Much of the debate around this topic focuses on Internet intermediaries or third parties that collect information – yes, NAI members. My mission is to educate the well-intentioned stakeholders involved and address their concerns, in the hope of avoiding the potential (if unintended) negative ramifications of some of their proposals. Although some at W3C frame this debate about OBA and third parties, the potential impact on the entire online ecosystem could be catastrophic with minimal gains for consumer privacy. I’m also concerned about how the new laws in Europe may impact the greater ecosystem if not implemented with the type of excruciating effort it takes to ensure proposed regulations do not unreasonably restrict the consumer experience and/or fair commerce and growth.
These challenges are just that: Challenges. As an organization, we’ll conquer them and grow stronger and smarter as a result. The industry evolves every day, and as long as we continue to champion what’s best for our members, consumers, and the internet advertising industry at large, we’ll continue to grow and thrive.
I truly believe this and, in June, find myself more energized and excited than I was in January. Thank you again for being a core part of the NAI’s success. While we have all committed to tackle complex challenges together, the people that are the NAI team and members make it an enormously enriching and memorable experience. Here’s to the road ahead!